S. 80-O: Royalties – Foreign enterprises -Technical assistance- Principal agent relationship -Information concerning industrial, commercial or scientific knowledge, experience or skill- Major information sent by the appellant to the Sumitomo Corporation was in the form of blue prints for the manufacture of dies for stamping of doors which is not entitle to deduction .
S. 80M : Inter corporate dividends -Only the actual expenses for earning dividend income ought to be taken and not on estimate basis .
S. 80IC : Special category States – Undertaking job work by providing labour and factory space to manufacturers of medicines is entitle to deduction .
S. 80IB: Industrial undertakings – Employment of number of workers – Question of fact was examined by the Tribunal, finding of fact .
S.80IA:Industrial undertakings — Income from advertisements on foot over bridges and bus shelters is entitle to deduction .
S. 80IA :Industrial undertakings – Infrastructure development-
Ownership of undertaking is not Important — Successor in business can claim deduction-Suggestion to tax administration -Revenue to host on their web site a plain English version of the enactment [ 80IA)(4) ]
S.80IA: Industrial undertaking – Infrastructure facility – – Container freight station ( CFS) is eligible deduction as an infrastructure facility – Strictures passed against Dept’s Advocate for “most unreasonable attitude” of seeking to reargue settled concluded issues and not following the judicial discipline and law of precedents .
S. 80HHC : Export business – Amendment with retrospective effect imposing conditions for exporters having turnover above Rs. 10 Crores , was held to be prospective in nature [ S. 28(i)]
S.80HHC: Export — Generation of profit in export business is irrelevant –Formula to be applied – Income from high sea sales to be included – Loss incurred in export business is eligible deduction [ S.80HHC (3) (c ) ]
S. 80HHC : Export business – Ninety per cent. of only net interest is to be Included in profits of business As Computed under head “Profits and gains of business.