S. 40(a)(i) : Amounts not deductible – Deduction at source -Non-resident -Interest on foreign currency Loan —Specific exemption from Ministry of Finance for interest —Not liable to deduct tax at source – No disallowances can be made .[ S.10(15)(iv)(f),37(1), 195 ]

S.37(1) : Business expenditure — Wholly and exclusively for the purposes of business – Donations made under Corporate Social Responsibility — Held to be deductible — Res Judicata — Not strictly applicable in Income-Tax proceedings — Consistency essential.

S. 36(1)(viia) :Bad debt-Provision for bad and doubtful debts – Schedule bank – Entitled to deduction to the extent provision is made in the accounts subject to the limit mentioned in S.36(1)(viia) of the Act .

S.36(1) (iii): Interest on borrowed capital — Amount borrowed advanced at lower interest — Revenue authorities cannot substitute their own wisdom or notion about the rate of interest agreed to between the parties – Interest is deductible .

S. 36(1)(iii) :Interest on borrowed capital – Borrowed from banks and advanced to sister concern- Commercial expediency – Sufficient interest free fund was available – Deletion of disallowance is held to be justified .

S.28(i) : Business income — Income from house property —Main business is let out of property – Income assessable as business income [ S.22 ]

S. 14A : Disallowance of expenditure – Exempt income – Notional expenditure on earning dividends cannot be disallowed when there is no expenditure is incurred – Rule 8D cannot be applied to any assessment year prior to assessment year 2008 -09 [ R.8D ]

S. 14A : Disallowance of expenditure – Exempt income – No disallowance if exemption has not been claimed.[ R.8D ]

S. 10A : Free trade zone – Export oriented undertakings – Remission or cessation of trading liability – Profits derived from export- Reversal of the entry with regard to the stock option given to the employees was in the nature of export income- Entitled to exemption. [ S.10B , 41(1) ]

S. 10(17A) : Awards and rewards in cash or kind – Award for meritorious service in Public Interest —Approval of State Government or Central Government is not mandatory – Approval is implied .