S. 40(a)(iib) : Amounts not deductible-Validity of provision-Exclusive Jurisdiction of High Court to consider-Cause of action for challenge to vires of provision arose on issue of show-cause notice-High Court is directed to dispose of writ petition on merits. [Art. 14, 226]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Non-resident-Interest-Usance charges paid on letters of credit issued by Indian Banks for import of raw materials-Income of non-Resident- Liable to deduct tax at source. [2(28A), 5(2), 9(1)(v)(b), 195(1)]

S. 37(1) : Business expenditure-Discount on Debentures-Principle of matching concept not applicable-Amount relating to relevant accounting year alone deductible as revenue expenditure. [S. 145]

S. 37(1) : Business expenditure-Capital or revenue-Contribution towards reconstruction of Bridge to enable transportation of assessee’s products to port-Allowable as revenue expenditure.

S. 37(1) : Business expenditure-Contribution made under specific directions of Government of India to other projects-Contributions to Provident Fund – Held to be allowable as deduction. [S. 36(1)(va), Electricity (Supply) Act, 1948, S. 24]

S. 37(1) : Business expenditure-Capital or revenue-Payment made to an entity under an agreement for additional infrastructure for augmenting continuous supply of electricity-No asset acquired-Held to be allowable as revenue expenditure.

S. 37(1) : Business expenditure-Legal and professional fees-Non export oriented units-Held to be allowable.

S. 37(1) : Business expenditure-Staking and handling expenses and blending and screening charges-Sister concern-Deletion of addition is justified.

S. 37(1) : Business expenditure-Capital or revenue-Expenses incurred for upgradation of computers and to acquire software-Held to be revenue expenditure.

S. 36(1)(viii) : Eligible business-Special reserve-Financial Corporation-Entitled to deduction. [Companies Act, 1956. S. 3, 617]