S.147 : Reassessment – Notice – Non-resident – Permanent-establishment – Tax deduction at source – Survey –Reassessment proceedings was held to be valid by High Court -Subsequent finding of DRP that there was no permanent of assessee in India , AO has dropped reasssement proceedings- Order passed by High Court up holding validity of proceedings was set aside- DTAA–India–Korea. [S.148, Art. 5 ]

S. 13 : Denial of exemption-Trust or institution- Investment restrictions -Shares received by way of gift failed to dispose off or convert said shares in to permissible investments – Denial of exemption is to be restricted to only income earned from shares to be taxed at marginal rate under S.164(2) and not on entire income of the assessee.[ S. 11,13(1)(d) (iii),164(2) ]

S.37(1): Business expenditure -Granting monetary benefit to legal heir of a former employee on the basis of resolution passed by the cpmpany is allowable as business expenditure .

S.37(1): Business expenditure – Capital or revenue- Product development expenses -Expenditure incurred improving quality of existing products – Held to be allowable as revenue expenditure .

S. 220 : Collection and recovery – Assessee deemed in default – Stay- Revenue authorities cannot pass an order mechanically referring the instruction no 1914 dt. 21-03 1996,directing the Assessee to pay 20 percent of amount during pendency of appeal before CIT (A)- Order of PCIT is set aside and reamnded to the PCIT to reconsider the application of stay and decide in accordance with law .[ S.251 ]

S. 220 : Collection and recovery – Assessee deemed in default – Stay- Power of stay with Appellate Authority cannot be equated to power garnted to the Assessing Officer- Petition was dismissed and directed to file stay petition before CIT(A )[ S.220(6), 251 ]

S. 147 : Reassessment- Charitable trust-Appeal agsint rejection of application for exemption of income was pending for next year- Reassessment notice for earlier years would not be vitiated by pending appeal against cancellation of application under S.13 of the Act .[ S. 11, 12AA, 13 , 148 ]

S. 36(1)(iii) :Interest on borrowed capital -Development and construction of residential building -Followed Accounting Standard- Disallowance of interest is not justified on the ground that interest on borrowings was included in closing work in progress .[ S.145 ]

S. 5 : Scope of total income -Accrual- Mercantile system of accounting -Not liable to be taxed on notional interest on non-performing assets considering the guidelines of Reserve Bank of India [ S. 145 ]

S.145: Method of accounting -Project completion method- Disclusure in the course of survey-Construction business- Income could be taxed only when sale deeds of units sold were registered even though sale consideration have been received earlier from buyer .[S.133A]