S. 40(a)(i) : Amounts not deductible-Tax deduction at source-Reimbursement of debtor collection charges-No permanent establishment-Not royalty or fees for technical services-No tax deductible at source-Reimbursement of legal expenses-Pure reimbursement-Matter remanded for verification-No double taxation.[S. 9(1)(vii), 195]

S. 40(a)(i): Amounts not deductible-Deduction at source-Non-resident-Royalty-Software purchased for resale-Right to use copyrighted article and not copyright-Payment not royalty-No tax deductible at source.[S.9(1)(vi), 195]

S. 37(1) : Business expenditure-Foreign travel expenses-Directors’ visit to overseas subsidiaries for promotion of business-Commercial expediency-Allowable-Irrecoverable excise duty on sales returns-Expenditure incurred for business purposes-Allowable-Gift and gardening expenses-Expenditure incurred for business purposes-Allowable-Prior period expenses-Assessee unable to establish crystallisation of liability during relevant year-Disallowance upheld.

S. 37(1) : Business expenditure-Glow signboards, sales tools and fixtures supplied to dealers-Expenditure revenue in nature-Royalty-Manufacturing business already established-Royalty paid for manufacture of two-wheelers-Revenue expenditure-Technical know-how-Expenditure incurred after commencement of manufacturing-Revenue expenditure.

S. 37(1): Business expenditure-Research programme-Payment for employees’ training and research-Expenditure incurred wholly for business purposes-Allowable-Advertisement and brand promotion expenses-Payment for use of established brand and designs-Revenue expenditure-Sponsorship expenses-Assessee failed to establish business purpose-Disallowance upheld.[S. 32]

S. 32 : Depreciation-Intangible assets-Goodwill-Business acquired on slump sale-Excess consideration representing business commercial rights-Depreciation allowable.

S. 32: Depreciation-Assets acquired from associated enterprise-Depreciation allowed in earlier years-Depreciation cannot be denied in subsequent year.

S. 28 (1): Business income-Duty drawback-Taxable in year of actual receipt-Matter remanded to avoid double taxation.

S.14A: Disallowance of expenditure-Exempt income-Sufficient interest-free funds available-No disallowance warranted. [R. 8D]

S.14A: Disallowance of expenditure-Exempt income-Dissatisfaction of Assessing Officer must be based on cogent reasons-Mere observation that disallowance is meagre is insufficient. [R. 8D]