S. 50C : Capital gains – Full value of consideration – Stamp valuation -Property purchased from the funds of the firm – Procuring agent and not owner – Addition cannot be made – Matter remanded for verification [ S.45 ]

S.45: Capital gains — Long-term capital gains —Sale of property taking place 11-4-2011 — Capital gains assessable in the year 2012-13 and not in the year 2008-09 . [ S. 2 (47 ) ]

S. 40(a)(ia): Amount not deductible -Deduction at source – Fees for professional or technical services – Discount offered to distributors – Non -Resident – Not liable to deduct tax at source- Allowable as expenditure [ S. 9(1) (vi), 37(1) , 194J , 195 ]S. 40(a)(ia): Amount not deductible -Deduction at source – Fees for professional or technical services – Discount offered to distributors – Non -Resident – Not liable to deduct tax at source- Allowable as expenditure [ S. 9(1) (vi), 37(1) , 194J , 195 ]

S. 37(1) : Business expenditure – Mobile handsets to employees , dealers and sales personal etc ,at free of cost – Allowable as business expenditure .

S. 37(1) : Business expenditure – Distributor – Trade price protection- Commercial expediency – Allowable as deduction .

S. 37(i) : Business expenditure —Provident fund- Contribution made after expiry of due date provided under Employees’ Provident Funds and Miscellaneous Provisions Act 1952 — Not allowable as deduction

S. 37(1) : Business expenditure – Education Cess — Not a tax- Allowable as business expenditure .

S. 37(1) : Business expenditure – Set up of business – Interest , administrative and other expenses is held to be allowable as deduction – Interest income is to be assessed as business income and interest expenditure to be set off against it. [ S.28(i) , 56 , 57 ]

S. 36(1)(iii) :Interest on borrowed capital -Inventories held as current assets —Method of accounting – Accounting Standard 2 — Interest expenses allowable as deduction .[ S.145A ]

S. 36(1)(iii) :Interest on borrowed capital – Reasonableness of expenditure has to be decided by assessee and not department – Sufficient interest-free funds- No disallowance can be made .