S. 11 : Property held for charitable purposes-If past-year discrepancies, if resolved, do not justify denying exemption in subsequent years. [Form 10B]

S. 11 : Property held for charitable purposes-Kuri and finance-Amount spent for object of the Trust-Entitle to exemption.[S.2(15)]

S. 11 : Property held for charitable purposes-Charitable purpose-Provision of credit guarantee for loans to micro and small enterprises-Entitle to exemption-Provision for guarantee claim-Allowable as deduction [S. 37(1)]

S. 11 : Property held for charitable purposes-Late filing of return-CBDT Circular clarifies that trusts are eligible for exemption u/s.11 even if the return is filed belatedly, provided it is filed within the time permitted u/s.139 (4A) [S. 139(4A)]

S. 10(38) : Long-term capital gains from equities-Penny stock-Accommodation entries-Failure of the Revenue to bring on record any materials linking assessee in any of the dubious transactions-Addition as cash credit is deleted.[S. 45, 68, 147, 148]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-US based company-amount received by assessee from Indian customers on account of sale of software solutions-not royalty income-DTAA-India-USA [Art. 12]

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Sales commission received by USA Company from Indian company-marketing services provided outside India-Cannot be considered as FTS under 9(1)(vii) and Article 12 of DTAA-Not taxable in India-DTAA-India-USA [Art. 12]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Assessee, US based company, had closed its Liaison Office (LO) operations in India and no business activity was carried out through the LO-Held, since assessee had no PE in India-Question of attribution of profits to PE in India did not arise-therefore, amounts paid by resident Indian end-users/distributions to the Assessee as consideration for resale/use of computer software through EULAs/distribution agreements, is not payment of royalty for use of copyright in computer software-DTAA-India-USA [Art.5]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-AO considered assessee as supervisory PE-estimated profit of 10% as profit rate on income earned and 25% as attributable towards PE-Held profits were taxable in India-ad-hoc percentage cannot be applied-matter set-aside to the Assessing Officer.