S. 35 : Scientific research-No product was manufactured in a particular unit-Allocation of expenses is held to be not justified-Research and development-Capital expenditure towards research and development R & said expenditure was to be excluded from toil capital expenditure while allowing expenditure on R & D units.

S. 28(i) : Business income-Electricity company-Electricity distribution-Efficiency gain amount which was not refunded to customers, said surplus fund being at disposal of State Electricity Regulatory Commission, could not be included in business profit. [S. 4]

S. 4A : Disallowance of expenditure-Exempt income-Insurance Company-Provision not applicable-Ground not raised before the Tribunal cannot be argued before the High Court. [S. 44, 260 A]

S. 14A : Disallowance of expenditure-Exempt income-Enhancement by the Assessing Officer-Considering the facts disallowance is held to be justified. [R. 8D]

S. 10AA : Special economic zones-Export turnover-Expenses incurred in foreign currency not meant for rendering any services outside India, could not be excluded from export turnover.

S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record-Hearing concluded on 23-7-2019 and order was passed on 18-10-2019-Monetary limit prescribed Circular Nos. 3 of 2018 dated 11-7-2018 ie. 20 lkhs would apply and not circular No 17 of 2019 dated 18-8-2019 wherein the monitory limit of Rs. 50 lakhs was fixed. [S. 268A]

S. 254(1) : Appellate Tribunal-Powers-Delay of 124 days was condoned-Mistake of counsel-Supported by affidavit-Delay was condoned-Ex parte order passed by the Commissioner (Appeals) was set aside and directed him to decide on merits. [S. 251]

S. 234E : Fee-Default in furnishing the statements-Prior to 1-6-2015-No fee can be levied. [S.200A]

S. 234E : Fee-Default in furnishing the statements-Tax deducted tax at source and deposited same on 18-5-2015 i.e. prior to amendment to section 200A(1) on 1-6-2015-Statement of TDS was filed on 23-6-2016-late fees could not be as default was prior to amendment. [S. 195, 200A (1)]

S. 201 : Deduction at source-Failure to deduct or pay-Bank-Interest paid to customer-Shown in their respective return-Should not be treated as an assessee-in-default-Matter remanded. [S. 194A, 197A, 201(1), 201(1A) Form No. 15G, 15H]