S. 69C : Unexplained expenditure-Bogus purchases-Purchase of newsprint-Ad hoc disallowance of 15 per cent. reduced to 5 per cent. by Tribunal-Assessee accepting 5 per cent. Order of Tribunal affirmed. [S.37(1), 56, 131, 153(3), 246A, 260A]

S. 69C : Unexplained expenditure-Bogus purchases-Information from Investigation Wing-Restriction of disallowance by Tribunal to 6 per cent. justified.[143(3), 147, Art. 226]

S. 69C : Unexplained expenditure-Bogus purchases-Only income component of disputed purchases taxable-Restriction of disallowance by Tribunal to six per cent. justified. [S. 132, 143(3) 147, 260A]

S. 68 : Cash credits-Share application-Identity, genuineness and creditworthiness of investors proved-Order of Tribunal is affirmed-Business expenditure-Income taxed twice-Order of Tribunal affirmed. [S.37(1), 133(6), 133A, 145(3), 260A]

S. 40A(3) :Expenses or payments not deductible-Cash payments exceeding prescribed limits-Cultivator and grower-Company engaged in pasteurisation not producer of milk-Disallowance was up held-Interpretation of taxing statutes-Principle of noscitur a sociis. [S. 260A, R.6DD(e)(ii)]

S. 40A(3) :Expenses or payments not deductible-Cash payments exceeding prescribed limits-Purchase of jewellery-Failure to show circumstances that required assessee to effect payments in cash-SLP of assessee dismissed. [R. 6DD, Art. 136]

S. 40(a)(ia): Amounts not deductible-Deduction at source-Commission-Discount-Not liable to deduct tax at source-Disallowance was deleted. [S. 260A]

S. 36(1)(iii) :Interest on borrowed capital-Installation of cell site towers Provision did not contemplate distinction between capital borrowed for revenue or capital purpose-Expansion of business-Matter remanded to Assessing Officer to examine aspects pertaining to common pool of funds as framed by Tribunal and cell sites actually brought into use. [S. 37(1), 260A]

S. 32 : Depreciation-Installation of cell site towers-Lease agreement-Accounting Standard 29-Entitle to depreciation.[S. 260A]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-
Deduction of tax at source-Transactions entered into pertaining to assessment years prior to introduction of Explanation in section 9(1)(vi)-Explanation 4 introduced in section 9(1)(iv) by Finance Act, 20121 cannot have retrospective effect and payment not royalty liable to deduction of tax-Appeal of revenue was dismissed. [S. 9(1)(vi), Expln. 4, 37, 40(a)(ia), 195(2).