S. 14A : Disallowance of expenditure-Exempt income-No exempt income received-Provision is not applicable. [R. 8D]

S. 10A : Free trade zone-Interest charges attributable to delivery of computer software-Excluded from export turnover-Deducted from total turnover-New unit-Entitle to deduction-Brought forward losses and unabsorbed depreciation-Deduction to be allowed before adjusting brought forward losses and unabsorbed depreciation. [S. 10A(2)(i), 10A(2)(ii)]

S. 10A : Free trade zone-Foreign exchange-Deductible from both export turnover and total turnover.

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Majority of services technical in nature-Services were ancillary and subsidiary to application or enjoyment of right, property or information for which royalty paid-Chargeable to tax in India-Liable to withhold tax-DTAA-India-USA-Netherlands [S.90, 92 to 92F, 195, Art, 12(5)(a)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Income will be assessed in the hands of PQR and STU and benefit of article 13 of the India-Netherlands Double Taxation Avoidance Agreement is not admissible to these funds will be assessed in the hands of PQR and STU and benefit of article 13 of the India-Netherlands Double Taxation Avoidance Agreement is not admissible to these funds-DTAA-India-Netherlands. [S. 2(17), 5, 60, 61, 62, 63(a), 160(1)(iv), Art, 13]

S. 4 : Charge of income-tax-Crabon credits-Capital receipts-Not taxable.

S. 234C : Interest – Deferment of advance tax – Tax deductible at source – Income which is subject to such deduction and is taken into account in computing total income of assessee.

S. 74 : Losses – Capital gains – Carried forward losses- Capital losses brought forward from earlier years pertaining to source of income that was exempt from tax was allowed to be carried forward to subsequent years- DTAA- India – Mauritius [ S.9(1)(i), 74(1)(a), 90(2) ,144C(5),Art . 13 ]

S. 271AAA : Penalty-Addition made on ad-hoc basis based on average gross profit rate, which does not relate directly to any undisclosed income unearthed during search-Penalty not sustainable. [S. 132, 133A]

S. 271(1)(c) : Penalty-Addition on basis of which penalty levied deleted.