S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Royalty-Advertisements on various non-resident Websites-Earning commission-Neither constitute permanent establishment nor royalty-Not liable to deduct tax at source-DTAA-India-Ireland.[S.195, Art, 12]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Membership/subscription fees to its group company GTIL-Sharing of expenses-Reimbursement of expenses-Not liable to deduct tax at source-DTAA-India-UK. [S. 9(1)(vi), 9(1)(vii), 195 Art, 13(4)]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Managerial services charges paid to Non-Residents not Liable to tax at source-Disallowance is not justified-Expenditure on management services-Allowable as business expenditure. [S. 195]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Fees for technical services-Examination fees from students-Foreign Universities-Directly remitted to the Universities-Not to be treated as technical services-Not liable to deduct tax at source-DTAA-India-UK-Switzerland. [S. 9(1)(vi), 90, 195, Art. 13]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Reimbursing salary of expatriates to foreign companies-not a fee for technical services-Disallowance not justified. [S. 9(1)(vii), 195]

S. 37(1) : Business expenditure-Commission-Consignment agents-Government departments-Allowable as deduction. [S. 147, 148]

S. 37(1) : Business expenditure-Coal handling charges-Matter remanded-Delay of 1234 days in filing the appeal was condoned. [S. 40(a)(ia) 254(1)]

S. 37(1) : Business expenditure-Commission payment-Consultancy charges-TDS was deducted-Payment by account cheque-Failure to provide the nature of service rendered-Disallowance of payment was affirmed.

S. 37(1) : Business expenditure-Commission-Documents produced-Direct nexus between commission paid and income generated-Even in the absence of any agreement with the commission agent, simply introducing or referring potential customers the commission payment is allowable as deduction.

S. 37(1) : Business expenditure-Capital or revenue-Product development expenses-Allowable as revenue expenditure-Provision for customer claims-Matter restored to Assessing Officer to examine claim in accordance with principles laid down by Supreme Court-Provision for bad and doubtful debts–Matter restored to Assessing Officer.