S. 37(1): Business expenditure-Technology licensing agreement-Payment initially capitalised as intangible asset-Expenditure held allowable as revenue expenditure- Foreign exchange loss-Expenditure arising from same business agreement-Revenue expenditure allowable. [Expln. 3 to S. 32(1)]

S. 37(1): Business expenditure-Employees’ Stock Option Plan-Discount on issue of shares-Revenue expenditure allowable- Entertainment and guest house expenses-No finding that expenditure was not incurred for business-Disallowance deleted.

S. 35: Expenditure on scientific research- Normal deduction under section 35(1) not dependent upon DSIR quantification-Weighted deduction restricted to expenditure approved by DSIR. [S. 35(2AB), 37(1) R.6(7A)]

S. 32 : Depreciation-Lease transaction-Commercial expediency cannot be questioned-Depreciation allowable.

S. 28(va) : Business income- Cash or kind-Under an agreement- Non-compete fee-Negative covenant-Capital receipt-Amendment taxing such receipt prospective-Not taxable.[S. 4]

S. 28(i): Business income-Rental income-Maintenance charges received under separate arrangement-Taxable as business income and not as income from house property. [S. 2(13, 22 44AD]

S. 23: Income from house property- Annual value-Property remaining vacant throughout year-Notional annual value assessable- Mere inability to secure a tenant throughout the year does not preclude assessment of notional rental income. [S. 22, 23(1)(a)]

S. 17(2): Salary- Perquisite- Rent-free accommodation-Existence of concession is a jurisdictional fact-Rule 3 cannot be invoked without such finding-n Indian Institute of Technology-Not Central Government employer-Rule applicable to Central Government employees not attracted. [S. 15, 17(2)(ii), R. 3 of the Income-tax Rules, 1962]

S.14A: Disallowance of expenditure- Exempt income-Dividend income-Investments made out of own funds-No interest disallowance-Administrative expenditure to be reasonably apportioned.[S.10(33), R.8D]

S. 9(1)(vii): Income deemed to accrue or arise in India- Fees for technical services-Non-resident-DTAA-Most Favoured Nation clause-Relevant date is date of treaty and not subsequent OECD membership-Treaty benefit denied- Corporate guarantee fee-Not managerial, technical or consultancy service-Not Fees for Technical Services- Reimbursement of social security contribution of seconded employees-Fees for Technical Services-Surcharge and education cess-Not leviable where treaty prescribes tax rate.-India-France.[S.90, Art. 12, 13]