S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Fes for technical services-Legal and consultancy services for registration of product in foreign country-Not fees for technical services-Not taxable in India-Not liable to deduct tax at source-DTAA-India-USA.[S.9(1)(vii),195 Art.12]

S. 37(1) : Business expenditure-Foreign exchange fluctuation losses-Hedging-Foreign exchange risks in respect of exports and imports-Loss is not speculative-Allowable as business loss.[S.28(i)]

S. 37(1): Business expenditure-Capital or revenue-Product registration expenditure-Revenue expenditure.

S. 37(1) : Business expenditure-Huge expenses of purchases, job-work payment, petrol and transport expenses Compared to preceding year-Failure to discharge the onus-Addition is affirmed.

S.37(1): Business expenditure-Capital or revenue-Stock brokerage-Expenditure on broadband, lease rent, software customisation, facility management, repair and maintenance-Allowable as revenue expenditure. [S. 32, 40(a)(ia)]

S. 36(1)(va): Any sum received from employees-Delayed payment of employees contribution to Employees’ State Insurance Corporation-Disallowance is affirmed.[S.43B]

S. 36(1)(iii) : Interest on borrowed capital-Sufficient interest free funds-Disallowance is deleted.

S. 36(1)(iii) :Interest on borrowed capital-Higher rate of interest 16% to bank on loans-Rate charged to subsidiaries lesser rate of 6%-Disallowance is deleted.

S. 36(1)(iii) : Interest on borrowed capital-Order of CIT(A) is affirmed.

S. 35 : Expenditure on scientific research-In-house scientific research and development-Weighted deduction-Expenditure attributable to income earned from contract research is also entitled to weighted deduction-Matter remanded. [S.35(2AB)]