S.2(14)(iii): Capital asset-Agricultural land- Adventure in the nature of land – Land was sold after a period of 16 months-Land shown as agricultural land in revenue records- Fact that said land had been sold to an industrial unit and had potential to be used for industrial purpose, could not be a determinative factor to treat profit earned by assessee on sale of agriculture land as business income- The intention of the purchaser cannot be the determinative factor to treat the profit earned by the assessee on sale of agriculture land as business income. .[ S.28(i), 45 ]

S. 69C : Unexplained expenditure -Cash payments – Amount offered as undisclosed income in return of mother-Deletion of addition is held to be justified .

S.69A: Un explained money- Performance charges in weddings- No evidence whatsoever or any incriminating documents which indicated attendance of marriage functions by assessee in absence of any corroborative material addition could not be made solely on basis of statement obtained from secretary of assessee .

S. 69 :Unexplained investments – Loose papers- Proposal to buy flat- Deal was cancelled – Addition is held to be not justified .

S. 44B : Shipping business – Non-residents – Inland Haulage Charges ( IHC)- Income derived from operation of ship in international traffic- Not taxable in India – DTAA- India -France [ Art.9 ]

S. 36(1)(iv) : Contribution to recognized provident fund – Contribution to provident fund which is constituted under Gujarat Co Operative Societies Act , 1961 is eligible deduction . [ S.2(38) 40A(9) , Gujarat Co-operative Societies Act, 1961 , S.71, 72 ]

S. 35AD: Deduction in respect of expenditure on specified business-Hotel business- Granted certification for categorization of its hotel as three star hotel -Entire capital expenditure is allowable as deduction .

S. 15 : Salaries – Salary paid to manging Director in excess of ceiling prescribed by as per Companies Act is taxable as salary provided the excess amount paid was not recovered by the Company .[ S.5 ]

S. 12AA : Procedure for registration –Trust or institution- Failure to dispose application with in prescribed period of six months – registration would be deemed to have been granted from date of inception of assessee-University. [ S.12A ]

S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Training services rendered by assessee to Indian Hotels could not be held to be technical services, nor same could have been characterized as ‘ancillary and subsidiary’ services – DTAA-India- Netherland [ Art .12(5)(a) ]