S. 40(a)(ia): Amounts not deductible – Deduction at source – Sale transaction trough dealers on principal -to -principal basis –Dealer could not be considered as commission agent of the assessee- Not liable to deduct tax at source- No disallowances can be made . [ S.194H ]

S.37(1): Business expenditure – Capital or revenue – Replacement of components of existing machinery to maintain efficiency and production capacity- Held to be revenue expenditure .

S. 36(1)(iii) :Interest on borrowed capital – Advance to sister concerns without interest – Having sufficient interest free funds – Disallowance of interest cannot be made .

S.28(i): Business loss- Sale of Fertilizer Bonds received as subsidy from Government in lieu of cash — Allowable as business loss . [ S. 2(14) ]

S. 246A : Appeal – Commissioner (Appeals) – Appealable orders – levy of interest – Appeal is not maintainable unless tax liability is challenged .[ S.220 (2) ]

S. 220 : Collection and recovery – Assessee deemed in default – Assessment order remanded – Levy of interest for period taken for re-computation is valid . [ S.156, 234A, 234B, 234C ]

S. 147 : Reassessment –With in four years-Notice based solely on report of District valuation Officer is not valid . [ S. 142A ,148 ]

S.147: Reassessment — After the expiry of four years- Notice issued within six years – escaped assessment of more than Rs .1 lakh – Not barred by limitation- Depreciation – No failure to disclose material facts – Change of opinion – Reassessment is bad on law . [ S. 32, 148 , 149(1) b) ]

S.143(3): Assessment – Trader transferring he goods to another trader. At a price less than the market price- Transactions showing loss – Addition cannot be made as income from undisclosed sources – No substantial question of law .[ S.260A ]

S.92C: Transfer pricing – Arm’s Length Price —Exclusion of comparables having high brand value is held to be proper .[ S.260A ]