S. 50C : Capital gains-Full value of consideration-Stamp valuation – Jantri value/circle rate of land was not higher than sale price agreed by assessee with purchaser, deeming provisions of could not be invoked. [S. 45, 48]

S. 37(1) : Business expenditure-Interest paid to income -tax department on delayed payment of Tax deduction at source is allowable as deduction, it is not personal tax. [S. 40(a)(ii)]

S. 36(1)(iii) : Interest on borrowed capital-Advance to subsidiary- Commercial expediency-Corporate strategy -Disallowance of part of interest is held to be not justified.

S. 14A : Disallowance of expenditure – Exempt income – No disallowance can be made in the absence of any exempt income earned during the year . [R. 8D]

S. 11 : Property held for charitable purposes – Accumulation of income- Application of income – Charitable trust is entitle to accumulate 15% of receipts without considering the expenditure incurred on objects of Trust – when the application of income, is more than receipts of year, excess application of income i.e., expenditure in hands of assessee, can be carried forward to succeeding year. [S. 11(1)(a), 11(2)]

S. 226 : Collection and recovery–Stay-AO cannot direct the Assessee to pay 20% of tax in dispute without application of mind [S. 225]

S. 205 : Deduction at source-Credit for tax deduction at source-Bar against direct demand–No recovery from the assessee for default committed by the deductor to deposit the tax deducted amount with the Government Treasury. Garnishee proceedings was quashed and directed the revenue to refund the amount recovered from the assessee. [S. 226(3)]

S. 147 : Reassessment-After the expiry of four years-Capital gains- Cost of acquisition -In absence of fresh tangible material and in the absence of failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment- Reassessment is held to be in valid. [S. 45, 49, 68, 148]

S. 143(2) : Assessment–Notice–Defective return-On removing the defects in the return with in time permitted relate back to the date of filing of original return -Limitation for issue of notice has to be from the date of filing of original return- Notice issued was held to be in valid. [S. 139(9)]

S. 80HHE : Export business-Computer software–Eligible business- While computing the deduction turnover of only eligible to be considered and not total turnover of business.