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1. Exemption u/s 11 - Charitable activity u/s 2(15) - Commercial activity - Citing past decisions favorable to the trust under similar assessments, the Tribunal reiterated...

2. Charitable purpose - subject to the provisions of section 11(1)(c) wherein the income applied outside India is also eligible for exemption, if the activities tend to...

3. Exemption u/s 11 - merely because the payments are made outside India, it cannot be said that the charitable activities were also conducted outside the country - the...

4. Income accrued in India - Salary income - services rendered outside India - AO objected that evidence was not produced for receiving the foreign allowance outside India...

5. The commission has been paid to non-resident outside India for services rendered outside India - where the non-resident agent operates outside India, no part of his...

6. Prohibited activities for investment by a person resident outside India - FDI - FEMA - New Regulations

7. Exemption u/s 11 - Grant of registration u/s 12AA - The provisions of section 11 (1)(c) comes into operation only once registration is granted u/s 12A of the Act and...

8. Denial of exemption u/s 11 - Assessee is claimed to be a trust carrying on activities of providing swimming pool facilities for aquatic events and training and...

9. Bifurcation of income from GMR Project in item of “inside India” and “outside India” - the outside receipts pertaining to designing, fabrication and supply of material,...

10. Income Accrue or arise in India - FTS - the ultimate delivery of the software was outside India - Since there is no dispute that the services were rendered outside India...

11. Income deemed to accrue or arise in India - non-resident corporate entity - Taxability of royalty income received by the assessee on subscribers units from original...

12. Assessee was liable to TDS u/s 195 while making payment thereof, since the export activities have been fulfilled in India, source of income was located in India and not...

13. Charitable purpose - the application of the fund is not made for charitable activity but for construction of the building, which again does not directly reflect the...

14. Income accrued in India - Article 15(1) of India-Austria DTAA agreement - if services are rendered outside India such income would not be taxable in India - the salary...

15. Charitable purpose - If the income is not applied for charitable activities and this factual aspect is not established, the registration does not help otherwise - HC