S. 40A(2): Expenses or payments not deductible – Excessive or unreasonable -Onus on assessing officer to bring on record comparable cases Assessee as well as holding company assessed to Income-tax at maximum marginal rate — Disallowance is not justified .

S.37(1): Business expenditure — Capital or revenue -Collaboration agreement for expansion of existing business — Project abandoned without acquiring any new asset for enduring benefit —Expenses allowable as revenue expenditure.

S.32: Depreciation — Goodwill —Goodwill in books of assessee on account of rounding off of decimal in share exchange ratio not an artificial one- Entitle depreciation.

S. 11 : Property held for charitable purposes –Educational activities- Denial exemption is not justified only on account of charging fees from students – Receipts cannot be assessed as income from other sources – The assessee is entitle to exemption.[ S.2(15), 12 , 56]

S. 10B: Export oriented undertakings – Delay of one month in filing return — System of assessee affected by virus —Entitled to exemption.[ S.139(1) ]

S. 271(1)(c) : Penalty – Concealment – Furnishing of inaccurate particulars of income — Mere rejection of claim — Penalty not leviable . [ 9(1)(vii) ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue -Loss in forward contract — Revision treating loss as speculative loss is not valid [ S.43(5) ]

S. 253 : Appellate Tribunal – Limitation —Application for condonation of delay was not supported by evidence – Appeal of revenue was dismissed .

S. 194A : Deduction at source – Interest other than interest on securities – Non-resident -External commercial borrowings with ICICI Bank Singapore Branch — ICICI Bank Indian resident company and its global income including offshore Branch Chargeable to tax in India – Not liable to deduct tax at source . Matter was set aside for verification .[ S.6(3), 194A (3) (iii), 195 , 201 (1) 201(iA) ]

S. 153A : Assessment – Search- No incriminating material was found in the course of search proceedings – Net agricultural income accepted during assessment proceedings — Addition cannot be made on net agricultural income .