S. 48 : Capital gains-Computation-Cost of acquisition-Indexation benefit on debt instruments-Government securities different from bond and debenture for purpose of third proviso to S.48-Benefit of indexation should be granted to assessee on redemption of government securities. [Public Debt Act, 1944. S. 2(a)(i)]

S. 45 : Capital gains-Gains from equities-Entire documentary evidence not disputed and no rebuttal to explanation of assessee-no adverse materials against assessee-No proper enquiry conducted on documentary evidence filed-Assessee entering into genuine transaction of sale and purchase of shares-Entitled to exemption. [S. 10(38), 68, 115BBE].

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Copy editing, indexing and proof reading requiring only knowledge of language and not expertise in subject matter of text-Services rendered by Non-residents not Technical Services-Not liable to deduct tax at source-No disallowances can be made. [S. 195(6)]

S. 40(a)(ia) : Amount not deductible-Deduction of tax at source–Payments to Non-resident–Services rendered outside India– Payments outside India-Not taxable in India-No disallowance can be made.0 OECD Model Convention – Art, 7 [S. 5, 9, 195]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Non-resident-Copy editing, indexing and proof reading requiring only knowledge of language and not expertise in subject matter of text-Services rendered by non-residents not technical services-Tax deduction is not required-No disallowance can be made. [S. 9(1)(1), 195(6)].

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Copy editing, indexing and proof reading requiring only knowledge of language and not expertise in subject matter of text-Services rendered by Non-residents not Technical Services-Not liable to deduct tax at source-No disallowances can be made. [S. 195(6)]

S. 37(i) : Business expenditure-Bogus purchases-Entire purchase and sale transactions duly recorded in regular books of account of all parties-Entire transactions routed through regular banking channels-No incriminating documents with respect to purchases and sales found in search-Purchases are genuine-Addition is held to be not justified.

S. 37(1) : Business expenditure–Method of accounting-Ad-hoc disallowances of general expenses without rejecting the books of account- No disallowances can be made.[S. 145]

S. 37(1) : Business expenditure–Commission to the HUF from whom unsecured loan was borrowed–Commission paid to HUF is an allowable expenditure.

S. 36(1)(iii) : Interest on borrowed capital-Interest-free loans to sister concerns-Interest-free funds available with assessee more than advance paid to its sister concerns-AO to decide in accordance with supreme court decision.