S.28(i) : Business income -Income from other sources – interest earned from investments with treasuries and banks was part of the banking activity of the assessee, and was eligible to be assessed as income from business [ S.56 ]

S. 14A : Disallowance of expenditure – Exempt income – Strategic Investment – Own funds more than investments -No disallowance can be made . [ R.8D ]

S. 14A : Disallowance of expenditure – Exempt income – Shares held as stock-in trade -Interest expenditure – Value its stock at cost or market value, whichever was lower -Matter remanded .[ S. 36(1)(iii), 115JB, R.8D (ii) ]

S. 11 : Property held for charitable purposes – Micro finance activity — Not charitable in nature — Not entitled to exemption [ S. 2 (15) ]

S. 9(1)(i): Income deemed to accrue or arise in India – Business connection – Royalty — Fees for technical services —Reimbursement of expenses- Held to be not taxable – DTAA-India – Singapore [ Art 5 (2) 12 ]

S. 4 : Charge of income-tax – Diversion of income by overriding title — Revenue sharing agreement- Holding company – Expenditure incurred towards services obtained from its holding company allowable as deduction .

S. 271C : Penalty – Failure to deduct at source – Non -resident – Short deduction of tax – levy of penalty is not justified when the assessee has deducted tax at source under S. 194IA instead of S 195 of the Act – Levy of penalty was deleted . [ S. 194IA ,195,201, 201(IA), 273B ]

S. 147 : Reassessment –With in four years- Client code modification- Reassessment notice is held to be bad in law. [ S. 68, 69C ,115BBE 143(1) 148 ]