S. 40(a)(ia): Amounts not deductible-Deduction at source-Building contractor-Capitalised the expenditure-Not disallowable.[S. 30 to 38, 143(1)(a), 194C]

S. 40(a)(ia): Amounts not deductible-Deduction at source-Job work-Furnished Form 16A-Addition was deleted.[Form No 26AS]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission payment outside India-: Income deemed to accrue or arise in India-Commission paid to non-residents for services rendered outside India is not taxable in India; hence, the assessee is not liable to deduct TDS under S. 195. [S. 9(1)(i), 195]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Reinsurance premium ceded to non-resident reinsurers (NRRs) is not taxable in India under the Income Tax Act or the applicable DTAA; therefore, disallowance under S. 40(a)(i) for non-deduction of TDS under S. 195 does not arise. [S.195]

S. 40(a)(i): Amounts not deductible-Deduction at source-Non-resident-Business profits-Canvassing orders and facilitating export transactions-Business income accruing outside India-Not liable to deduct tax at source-No disallowance can be made.[S.9(1)(i), 195, Article 7 of the OECD Model Convention]

S.37(1): Business expenditure-Commission-Allowable as deduction.

S.37(1): Business expenditure-Marketing support expenses-Director’s remuneration-Allowable as business expenditure.

S. 36(1)(va): Any sum received from employees-Delayed employees’ PF/ESI contributions on ground that figures in Form 3CD included both employer’s and employees’ portions-Matter was remanded to the file of CIT(A) to verify actual delay, segregate employer’s and employees’ contributions, and restrict disallowance only to employees’ share deposited after statutory due dates.[S.43B, 143(1)]

S. 36(1)(iii): Interest on borrowed capital-Advances to group concerns at lower interest-No disallowance if assessee’s own funds exceed interest-free advances-Nexus established between borrowings and business use-Ad hoc disallowance based on average rate unjustified-Addition is deleted. [S. 40A(2)(b)]

S. 36(1)(iii): Interest on borrowed capital-Commercial expediency-Disallowance is deleted.[S.37(1)]