S. 61 : Revocable transfer of assets-Trust-Association Of Persons-Stressed Assets Of Banks And Financial Institutions Acquired By ARCIL by setting up Trusts and formulating schemes-Trust is not an Association of persons-No discretion is given to trustee to decide allocation of income every year, nor right given to beneficiary to exercise option to receive income or not-Income liable to be assessed in hands of beneficiaries-Respective shares known since inception-Assessee could not be considered as an indeterminate trust. [S. 63, Indian Trusts Act, 1882, S. 7, 9, Securitisation And Reconstruction Of Financial Assets And Enforcement Of Security Interest Act, 2002]

S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Excess cash, stale drafts and branch suspense account-Transferred to depositors’ education and awareness fund-Cannot be treated as income-Deletion of addition is affirmed. [S.28 (iv)]

S. 40(a)(ii) : Amounts not deductible-Rates or tax-Education cess-Not an allowable deduction.

S. 40(a)(ia): Amounts not deductible-Deduction at source-Making Provision for expenses at end of accounting year-No tax deducted at source-Deducting tax at source in subsequent year and depositing it before due date for filing of return of income.[S.139(1)]

S. 40(a)(ia): Amounts not deductible-Deduction at source-Interest-Payment of deposits-Disallowance of 30 per cent of interest-Deductees have already filed return and paid tax-Matter remanded. [S.194A, 197, Form 15 G, 15H]

S 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission-Procurement of orders overseas-No disallowance can be made for failure to deduct tax at source.[S. 5,9(1)(vii),195]

S. 37(1):Business expenditure-Diversion of income by overriding title-Payment made to sister concerns not out of its own discretion but made due to obligation arising out of agreement-Claim revenue neutral because assessee claimed sum as business expenditure and recipients of that sum had offered it, in aggregate, as income-Adding it in hands of assessee would be double addition-Expenditure allowable. [S. 4]

S.37(1): Business expenditure-Employees’ Stock Option Scheme Expenses-Disallowance is deleted.

S.37(1): Business expenditure-Corporate Social Responsibility expenses-Disallowance is justified-Qualified Institutional placement expenses-Matter remanded. [Companies Act, 2013, S.135]

S.37(1): Business expenditure-Employees stock option plan compensation expenses-Allowable as deduction.