S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Export commission-Sales, marketing and customer support services rendered outside India by foreign agents-Cannot be treated as Fees for technical services-Not liable to deduct tax at source-DTAA-India-Korea.[S.9(1)(vii): Art. 13]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Software training services outside India-Not required to deduct tax at source-OECD Model Convention, Article 12. [S. 9(1)(vii)(b), 195]

S. 37(1) : Business expenditure-Robbery-Theft-Embezzlement-Business of gold-Loss arising from robbery-Incidental to normal business-Allowable as deduction. [S.28(i)]

S. 37(1) : Business expenditure-Advertisement expenditure-Hospital-Unethical acts-Violation of provisions of Indian Medical Council Act, (professional conduct, Etiquette and Ethics) Regulations, 2002-Not allowable as deduction.

S. 36(1)(va): Any sum received from employees-COVID-19-Delay in depositing the amount-EPF Organisation had waived levy of penal damages for delayed payment during lockdown-Disallowance is deleted. [S.43B]

S. 28(va) : Business income-Cash or kind-Under an agreement-Non-compete fee-Joint venture company-Negative covenant-Loss of source of income-Capital receipt-Finance Act, 2002, with effect from 1-4-2003 applicable only after the assessment year 2003-04. [S. 4]

S. 28(i) : Business loss-Embezzlement of stock by an employee-FIR is filed-Loss is allowable as business loss. [S. 37(1), 145]

S. 28(i) : Business income-Capital gains-Own capital-Share dealings-Assessable as business income.[S. 45]

S. 13 : Denial of exemption-Trust or institution-Investment restrictions-Purchase of luxury vehicle-Registered in name of manging trustee-Not able to establish that vehicle was utilized for purpose of charitable activities-Exemption under sections 11 and 12 is denied on value of vehicle purchased [S. 11, 12, 13(1)(c)]