S. 4: Income chargeable to tax- Share application money- The Interest accrued from share application money has statutorily required to be kept in separate account and was being adjusted towards the cost of raising share capital against public issue expenses . [ S. 56, 145 ]

S.4: Income chargeable to tax – Diversion of income by overriding title- Acted only broker -For determination of taxable income , written agreement is not relevant, conduct of parties can be considered accordingly only income that has actually accrued to the assessee is taxable. [ S. 5,145 ]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-DTAA-India & Belgium–Issuing gradation certificate, the payment cannot be characterize as fees for technical services, not liable to deduct tax at source-DTAA-India- Belgium [S. 9(1)(vii], Art.
12,13]

S. 4 :Charge of income-tax – Capital or revenue- Sales tax subsidy is a capital receipt. [ S. 264 ]

S. 4 : Charge of income-tax -VAT subsidy -Refund of value added tax was held to be capital receipt and not chargeable to tax . [ S. 2(24)(xviii) , 43(1) ]

S. 4 : Charge of income-tax -Accrual – Interest on project advance –Development agreement has not taken place as the interest has not accrued, income cannot be assessed on hypothetical basis [ S.145 ]

S. 4 : Charge of income-tax – Capital or revenue- Notional sales tax – Question of law [ S. 260A ]

S. 4 : Charge of income-tax –Capital or revenue – Causal and non –recurring- Capital gains- Compensation paid for breach of contract was held to be capital in nature [ S. 2(24), 10(33) 45. 55(2)(a) ]

S. 4 : Charge of income-tax -Mutual concerns –Surplus earned was spent for common benefit of members of for carrying on objects of the Club – Principle of mutuality is applicable and surplus cannot be brought to tax .

S. 4 : Charge of income-tax – Interest on amount of sundry debtors outstanding cannot be charged on accrual basis [ S. 145 ]