S. 11 : Property held for charitable purposes-Application for registration for pending before CIT(E)-Pendency of appeal before CIT(A)-Justified in rejecting exemption. [S. 12A(2), 12AA]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Royalty-Reimbursement of expenses-Costs recovered by assessee a non-resident for third party software which was integrated into assessee’s information technology infrastructure used for rendering services to an Indian company, would be taxable as fees for technical services/Royalty-DTAA-India-Switzerland. [S. 9(1)(vi), Art. 12]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Offshore maintenance and support services to Power Grid Corporation of India Ltd. (PGCIL)-Not assessable as fees for technical services-DTAA-India-USA. [Art. 12(4)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Merely provided alloys, lease rentals received for such leasing out of alloys could not be treated as royalty-DTAA-India-USA. [Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Right to use of copy right in a program-Information products and services-Not royalty-DTAA-India-USA. [Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Consideration for resale / use of computer software-Payment is not payment of royalty-Not taxable in India-Not liable to deduct tax at source-DTAA-India-USA. [S. 195, 201(1), 201(IA), Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty Business of transmitting telecommunication signals to/from its customers-Income earned was not in nature of royalties-Not liable to tax in India-DTAA-India-USA. [Art. 12(3)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Support service-Outsourcing of work to India would not give rise to a fixed place PE-DTAA-India-Mauritius. [Art. 5]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Shipping business-Indian company an agent of independent status-Cannot be assessed as Agency PE of the assessee-DTAA-India-Mauritius. [Art. 5(5)]

S. 245 : Refund- Set off of refunds against tax remaining payable -Adjustment made without prior intimation is held to be bad in law .[ Art , 226 ]