S. 40(a)(ia) : Amounts not deductible-Deduction at source–Payee filed the return and offered the sum received from the assessee – Second proviso to section 40(a)(ia) has retrospective effect from 1-4-2010-No disallowances can be made. [SD. 194J, 201]

S. 37(1) : Business expenditure-Illegal Commission-Volcker Committee Report – No finding that the asesee had made payment – Deletion of addition held to be justified.

S. 37(1) : Business expenditure–Financial services-Sub–brokerage– Disallowance of 10% sub brokerage is held to be justified.

S. 37(1) : Business expenditure–Provision for project expenses – TDS was also deduced – Held to be allowable. [S. 145]

S. 36(1)(iii) : Interest on borrowed capital–Failure to establish that the expenses related to Hotel business was her proprietorship business – Disallowance was confirmed.

S. 36(1)(iii) : Interest on borrowed capital–Investment in acquiring control of two companies–Disallowance of expenditure on imaginary income and expenditure of subsequent year is held to be not justified – Expenditure is held to be allowable. [S. 14A, 57]

S. 14A : Disallowance of expenditure-Exempt income-Unless and until there is receipt of exempted income for concerned assessment year, section 14A is not attracted.[R. 8D]

S. 14A : Disallowance of expenditure – Exempt income – Applicability of Rule 8D is not mandatory in every case where assessee earns tax free dividend income – Rule 8D cannot be invoked and applied unless Assessing Officer records his dissatisfaction regarding correctness of claim made by assessee in relation to expenditure incurred to earn exempt income. [S. 10(34), R.8D ]

S. 10B : Export oriented undertakings-Deemed exports-Export through third parties-Entitled to deduction.

S. 4 : Charge of income-tax – Sales tax waiver benefits are in nature of capital receipts.