S. 10B : Export oriented undertakings-Separate books of account-No disallowance could be made-Matter remanded.

S. 10AA : Special Economic Zones-Amount written back on account of unclaimed balances-Brought forward losses not to be reduced from profits of current year. [S. 10A]

S. 10A : Free trade zone-Additions agreed under Mutual Agreement Procedure-Entitled to benefit of deduction-Export turnover-Total turnover.

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Sale of software-No specific finding with regard to licence agreement-Matter remanded.

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Payments for services relating to Hotel Management-Not taxable as fees for technical services-DTAA India-USA. [Art. 7, 12]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Intermediary services-No technology made available-Not fees for technical services-Not taxable in India-Sale of equipment and payments carried outside India-Income attributable to Permanent Establishment is not taxable-DTAA-India-Sweden. [S. 9(1)(i), Art. 12]

S. 4 : Charge of income-tax-Foreign currency-Convertible bonds-Buy back of foreign currency bonds at discounted price-Foreign currency convertible bond proceeds were utilized for setting up a new manufacturing facility or expansion of manufacturing facility-Discount is capital receipt. [S. 28(i)]

S. 2(22)(e) : Deemed dividend-Not shareholder of company which had advanced loan to assessee-Loan cannot be treated as deemed dividend.

S. 40 (a)(iib) :Amounts not deductible- Fee- Tax – Gallonge fee , licence fee and shop rental (KIST ) with respect to EL-9 and E.L -I licence granted will fall with in the purview of section and hence disallowable -Surcharge on Sales tax and turnover tax is not fee or charge hence not disallowable – Interpretation of taxing statutes – Same statute using different terms and expressions – Must be taken to refer to distinct and different things . [ S. 37(1)), Kerala Abkari Act, 1077 (M.E.) S. 18 , Kerala Foreign Liquor Rules , 1953 , R. 15A ]

S. 271D : Penalty-Takes or accepts any loan or deposit-Whatsapp messages-Employee and promoter of group-Receipt of cash not proved-Penalty cannot be levied. [S. 269SS]