S. 44B : Shipping business-Non-residents-Computation-Inland haulage charges-Part of income from operation of ships in international traffic-Charges received from transportation of cargo through feeder vessels-Not taxable in India-income from IT support services-Matter remanded-DTAA-India-France. [S.9(1)(vii), Art.9(1), 13]

S. 40(a)(ia): Amounts not deductible-Deduction at source-Cost of products manufactured-Not chargeable to tax-Not liable to deduct tax at source-DTAA-India-USA [S. 9(1)(v), 9(1)(vi), 195, Art. 12]

S. 35 : Expenditure on scientific research-Application for extension of approval is denied-Not eligible for deduction under section 35(2AB) on such R&D expenditure.[S.35(2AB)]

S. 32 : Depreciation-Robotix kits-Not computer-Entitle to deprecation at 15 percent only-Prior period expenses-Depreciation is not allowable-Travelling expenses-Self made vouchers-Disallowance is restricted to 10%. [S. 37(1)]

S. 28(i) : Business income-Interest on FDRs-Pledging fixed deposit receipts (FDRs) as margin with bank-Trading in crude palm oil (CPO)-Foreign Letters of Credit (FLCs) for oil import-Interest is assessable as business income and not as income from other sources-High sea sale-whether speculative-Not decided. [S.43(5), 56]

S. 12AA : Procedure for registration-Trust or institution-Pendency of assessment-CBDT Circular No. 1/2015-Entitle for exemption. [S.10(23C)(iiiad), 11, 12A]

S. 12AA : Procedure for registration-Trust or institution-Benefit of a particular sub-caste-Private religious trust-Rejection of registration is held to be justified.

S. 10AA : Special Economic Zones-Amendment in section 10AA(1) vide Finance Act, 2023 with effect from 1-4-2024-Exemption cannot be denied for not filing return of income within due date specified under section. 139(1) of the Act.[S.10AA(1), 139(1)]

S. 10 (23C): Educational institution-Registration-Matter remanded to the PCIT to consider whether such College and School could be treated as an independent entity under section 10(23C)(vi) in absence of separate PAN numbers.[S. 10(23C)(vi) 12AA]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Supply of equipment-Offshore sale of goods-Not taxable as FTS-DTAA-India-Ireland. [S. 5, 9(1)(vi), Art. 12]