S. 28(i) : Business loss-Write-Off of Loss-Investment made in subsidiary abroad-Commercial expediency -Transfer pricing adjustment -Book profit -Provision for doubtful debts -Remanded to the Assessing Officer- Question of facts. [S. 37(1), 92C, 115JB, 260A]

S. 14A : Disallowance of expenditure – Exempt income – Only Investments yielding income can only be taken into account -CBDT Circular dated 11-2-2014(2014) 361 ITR 94 (St), cannot override provisions of Section 14A and Rule 8D. [S. 119, R.8D(2)(iii)]

S. 11 : Property held for charitable purposes- Res Judicata -Rule of consistency-Benefits granted in earlier years-Order of Tribunal affirmed. [S. 12, 260A]

S. 11 : Property held for charitable purposes-Imparting education-Surplus in educational activities-Alleged excess remuneration to trustee employees-Revenue has no power to interfere-Exemption cannot be denied -Order of High Court affirmed. [S. 2(15), 12A, 13, Art. 136]

S. 10(38) : Long term capital gains from equities -Sale of shares- Capital gains -Income from other sources -Deletion of addition by the Tribunal is justified -Question of fact. [S. 45, 56, 260A]

S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty –
Non-Resident – Import of licensed software directly supplied by foreign vendor to end-user in India under exclusive licences -Not liable to deduct tax at source. [S. 195, 201(1)]

S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty Import of licensed software under exclusive licences -Not royalty -Not liable to deduct tax at source- Pendency of Review petition -SLP of Revenue was dismissed. [S.195, 201 (1), Art, 136]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Transferee authorised to use licensed software-No transfer of Copyright-Amount received is not royalty-DTAA-India-USA- SLP of Revenue dismissed. [S. 90(2) Art, 12, Art, 136]

S. 4 : Charge of income-tax -Entrance fees paid by Member -Capital receipt. [S. 28(i), Art, 136]

S. 2(14)(iii) : Capital asset-Agricultural land-Capital gains-agricultural lands converted for non-agricultural purpose-lands did not fall within 8 kms from Municipality of Bangalore-Continued agricultural operation-Mere inclusion of land in Special Zone without any infrastructure development does not convert land into non-agricultural land-Not liable to capital gain tax -SLP of Revenue dismissed. [S. 45, Art. 136]