S. 14A : Disallowance of expenditure-Exempt income-Disallowance made voluntarily was more than exempt income-No further disallowance can be made-Delay of 340 days-SLP of Revenue is dismissed on account of delay in filing of SLP-Question of law, if any is kept open. [R.8D, Art. 136]

S. 14A : Disallowance of expenditure-Exempt income-Interest free funds-Presumed that investments were made out of interest-free fund-Disallowance cannot be made-Order of High Court is affirmed-SLP of Revenue is dismissed. [R. 8D, Art.136]

S. 14A : Disallowance of expenditure-Exempt income-Borrowed capitals-Investing in shares to earn income from dividend-Expenditure incurred on interest paid on borrowed funds is not allowable as deduction-SLP of assessee is dismissed [S.10(33), 36(1)(iii), Art. 136]

S. 11 : Property held for charitable purposes-Donations other charitable institutions-Out of accumulated income-Direction as part of corpus donations-Not hit by Explanation 2 to section 11(1) of the Act. [S.11(1), 11(2), 11(3), 11(3)(d), 260A]

S. 10A : Free trade zone-Rental income-Sub lease of two units-Eligible for inclusion in profit as they were intimately connected with business of undertakings-SLP of Revenue is dismissed. [Art. 136]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Software-Sub-contracted certain overseas subsidiary-Not liable to deduct tax at source-No substantial question of law. [S. 195, 201(1), 201(IA), 260A]

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Software-Sub-contracted certain overseas subsidiary-Not liable to deduct tax at source-Special leave petition filed against said order of High Court is dismissed was to be dismissed as there is gross delay of 296 days and also on merits.[S. 195, 201(1), 201(IA), Art. 136]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Fees for technical services-Non-resident-Computer software manufacturer/supplier for resale/use of computer software through distribution agreements-Payment did not amount to royalty for use of copyright in computer software-Not taxable in India-Not liable to deduct tax at source-No substantial question of law-DTAA-India-Finland [S.9(1)(vii), 195, Art.12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Amounts paid by resident Indian end-users/distributors to non-resident computer software manufacturers/suppliers-Consideration for resale/use of computer software through EULAs/distribution agreements-Not payment of royalty for use of copyright in computer software-Not liable to deduct tax at source-DTAA-India-USA. [S. 9(1)(vii)),195(2), 260A Art. 12]

S 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Fees for technical services-High Court held that if rate of tax applicable under DTAA is lower than 20 per cent tax rate as prescribed under section 206AA, TDS has to be deducted at such lower rate even if non-resident deductee fails to furnish its PAN-DTAA-India. [S. 9(1)(vii), 90, 206AA, Art. 12]