S. 32 : Depreciation – Injection moulding machine falls under the category of ‘Moulds’ and therefore shall qualify for higher rate of depreciation.

S. 32 : Depreciation – Depreciation is allowable non-compete territory rights – Department’s action of not filing an appeal against the CIT(A) favourable order in earlier year gives finality to the dispute.

S. 14A : Disallowance of expenditure – Exempt income – No automatic disallowance can be made[ R.8D].

S. 14A : Disallowance of expenditure – Exempt income -Disallowance has to be made where the assessee cannot furnish any evidence to prove that the investments were made in earlier years.[ R. 8D]

S. 10AA: Special economic zones -Assessee manufacturing different items in different units – No dispute about unit wise profitability declared by assesse – Remand report accepting cost of goods were reconciled – Addition made by AO to be deleted.

S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty – Consideration paid for copyrighted article is not royalty and hence cannot be brought to tax either under Act or under DTAA

S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty – Royalty income of assessee earned from OEMs situated outside India for the patents licensed to OEMs for manufacture of CDMA Network outside India was not chargeable to tax u/s 9(1)(vi)(c) .

S. 4: Charge of income-tax –Capital or revenue -Entertainment subsidy received under Uttar Pradesh Government scheme for promotion of construction of multiplexes is a capital receipt.[S.2(24)]

S. 2(15): Charitable purpose – Applicability of proviso to S. 2(15) of the Act is a question of fact and should be decided on facts of the case and no generalization is possible. [ S.11, 12 ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue -Bogus purchases- Hotel business- information from sales tax authorities -Hawala Traders – Assessee offering 15% of gross profit in the course of assessment proceedings with a view to buy peace and unending litigation which was accepted by the Assessing Officer without making any inquiry – Commissioner revising the order on the ground that on there was no discussion in the order of Assessing Officer and the Assessing Officer limiting addition under S.69C only on basis of GP ratio is held to be not justified -Tribunal affirming the revision order -High Court affirmed the order of the Tribunal . [ S.69C ]