S. 44BB : Mineral oils-Computation-Non-Resident-Royalty-Charter of Vessel with crew for mineral oil extraction-Revenue earned from charter hire charges not royalty-Receipts of reimbursement intricately linked to chartering income-Not taxable-DTAA-India-Singapore. [S. 9(1)(vi), Art. 8(4)(b), 8(4)(c)]

S. 44BB : Mineral oils-Computation-Presumptive tax-Non-resident having Permanent Establishment in India-Income from contracts for processing of marine seismic data, seismic data acquisition and processing, hiring of vessel and technology-Taxable on presumptive basis-Advance tax-Non-resident not chargeable with interest. [ S. 9(1)(vii) , 44DA, 234B ]

S. 44AD : Presumptive basis-Cash credits-Not required to maintain books of account-No addition can be made-Provision of section 115BBE cannot be applied-Opening capital cannot be added as income from undisclosed sources-Failure to file proof-Deduction under 80C cannot be allowed. [S. 68, 69, 115BBE]

S. 40(a)(ia): Amounts not deductible-Deduction at source-Selling holiday membership plans to members-Matter remanded to the Assessing Officer for verification-Amendment with effect from 1-4-2015 providing for disallowance of thirty Per Cent. of expense to apply for Assessment year 2015-16 and subsequent years-Assessing Officer is directed to apply amended provision.

S. 40(a)(ia): Amounts not deductible-Deduction at source-Selling holiday membership plans to members-Matter remanded to the Assessing Officer for verification-Amendment with effect from 1-4-2015 providing for disallowance of thirty Per Cent. of expense to apply for Assessment year 2015-16 and subsequent years-Assessing Officer is directed to apply amended provision.

S. 40(a)(ia): Amounts not deductible-Deduction at source-Unexplained expenditure-Project payment to housing society-No supporting evidence-Disallowance is affirmed-Levy of concealment penalty is affirmed [ S.69C 271(1)(c) ]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Interest-Royalty-Fes for technical services-Foreign remittances Failure to file Forms 15CA and 15CBB-Reimbursement of expenses-Disallowance is not justified . [ S. 195 , Forms, 15CA, 15CB ]

S. 37(1) : Business expenditure-Setting up of business Commencement of business-Once the business is set up expenditure is fully allowable subject to verification that assessee had not claimed depreciation thereon and expenditure not claimed in any other year-Payment for expenses against corporate cards given to managerial personnel-Bills not received and expense written off as bad debts-Allowable as business expenditure. [S. 28(i), 32, 35D, 36(1)(vii), 145]

S. 37(1) : Business expenditure-Employees’ Stock option expenses-Allowable as deduction-Donations to charitable institutions-Corporate Social Responsibility expenses-Allowable under section 8OG ]

S. 37(1) : Business expenditure-Capital or revenue Loan processing charges paid to bank-Loan utilised for business purposes-One-time payment-Not capital expenditure.