S.14A : Disallowance of expenditure-Exempt income-Investments not yielding exempt income to be excluded in computing disallowance — Disallowance to be restricted to exempt income earned.[R.8D]
S.14A : Disallowance of expenditure-Exempt income-Investments not yielding exempt income to be excluded in computing disallowance — Disallowance to be restricted to exempt income earned.[R.8D]
S. 11 : Property held for charitable purposes-Depreciation —No double deduction claimed-Disallowance of depreciation is to be reversed.[S.11(6), 12A]
S. 11 : Property held for charitable purposes-Depreciation — No capital expenditure claimed in earlier years — Depreciation is allowable. [S. 2(15), 11(1)(a), 32]
S. 10(10AA) : Leave salary-Employee of the Central Government or State Government-Originally employed by Government but retiring from service of Government undertaking-Whether Entitled To Full Exemption — Matter remanded to Assessing Officer-CIT(A) has the power to entertain fresh claim which is not made in the return.[S. 143(1), 250]
S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Not adding any value to laboratory report but acting as medium to procure report from laboratory having higher credibility — Not fees for technical services.
S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Income from software sales and support services — Addition is deleted-DTAA-India-Singapore.[art. 12(4)]
S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Permanent Establishment —Attribution of profit is without any basis.
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Dependent agency permanent establishment — Remunerated by the assessee for commission activities on arm’s length basis, no further attribution was required. The Assessing Officer was directed to delete the addition.
S. 4 : Charge of income-tax-Block of assets-Assessee reducing Block of assets from item and claimed depreciation on reduced Block of asset — Addition is not sustainable.[S. 2(11)]
S. 4 : Charge of income-tax-Interest received on deposits in Consolidated fund of India-Not chargeable to tax-Directed the Assessing Officer to verify the facts.[S.143(3)]