S. 36(1)(iii) :Interest on borrowed capital – 15% rate of interest was paid on borrowed capital – Allowable as deduction on principle of commercial expediency .[ S.37(1) ]

S. 36(1)(iii) :Interest on borrowed capital -Amount borrowed utilised for purchase of capital assets — Interest is deductible .

S. 35 : Scientific research – Weighted deduction —Date of approval is not relevant — Application for approval in December 2006 and approval was granted in October 2008 — Entitle to weighted deduction.[ S.35(2AB) ]

S. 32: Depreciation -Plant and machinery put to use in April 1992 — Depreciation is not allowable for the assessment Year.

S. 17 : Perquisite – Salary-Employees deputed abroad — Extra payment to meet costs constitute perquisites- Liable to deduct tax at source . [ S.15,17(2), 192 ]

S. 17 : Perquisite – Salary-Employees deputed abroad — Extra payment to meet costs constitute perquisites- Liable to deduct tax at source . [ S.15,17(2), 192 ]

S. 14A : Disallowance of expenditure – Exempt income -Tribunal remanding the issue of interest expenses and deleting other expenses-– Order of Tribunal is up held – No question of law [S. 254(1) , 260A, R.8D ]

S. 10A : Free trade zone – Depreciation and other deductions –
-Neither any deduction claimed by assessee for Assessment Years prior to amendment nor exemption granted — Ten years’ relief allowed by later amendment in 2003 —Interpretation- Legislative intent – The intent of the Legislature while it made those amendments was not to curtail the relief to an assessee, who had not availed of double benefit- Matter remanded to Appellate Tribunal for reconsideration. [ S.10A(6) ]

S. 10(14) : Special allowance or benefit -Allowance received by employee to cover expenses incurred wholly in performance of duties —Extra payment to meet costs in Foreign location is not entitled to exemption. [ S.15, 17 , 192 ]

S. 9(1)(i): Income deemed to accrue or arise in India – Permanent Establishment -Global payment solutions facilitating use of electronic forms of Payment, ie by credit card, instead of cash and cheques -Banks and financial Institutions – There was a fixed place permanent establishment, service permanent establishment and dependent agent permanent establishment-On such attribution of income to the permanent establishment, the tax was required to be withheld at full applicable rate at which the non-resident is subjected to tax in India. Even automatic equipment like server can also create a permanent establishment and there was no requirement of human intervention- DTAA-India -Singapore [ Art. 5, 7, 12 ]