S. 69A : Unexplained money – Client code modification – Commodity broker – Statement was retracted – Deletion of addition is held to be justified [ S. 132 (4), 153A, 260A ]

S. 47(v) : Capital gains – Transaction not regarded as transfer – Subsidiary to holding company – 25% of share holding is held by nominee share holding of holding company – Exemption cannot be denied [ S.45 ]

S. 40A(3) : Expenses or payments not deductible – Cash payments exceeding prescribed limits – Bank account was attached – Disallowance of 20% is held to be not justified [ R.6DD(j)]

S.40(a)(iib):Amounts not deductible- Royalty, licence, fee, etc. (Gallonage fee, licence fee and shop rental (kist)) -Disallowable – licence granted to assessee for retail trade could not be sustained – Surcharge on sales tax- Surcharge on sales tax or turnover tax paid by assessee-company was not a ‘fee or charge’ coming within sweep of section 40(a)(iib), thus, same could not be disallowed . [ S.37 (1) ]

S. 40(a)(ia): Amounts not deductible – Deduction at source – Payment to contractor – Belated filing of form No 26Q- No disallowance could be made for failure to deduct tax at source [ S.194C (c)]

S. 37(1) : Business expenditure –Capital or revenue – Expenditure of lease premises – Allowable as revenue expenditure .

S.35: Scientific research – Directed the petitioner to make representation before the competent authority and the Competent was directed to consider the said application with in four weeks of receipt of the application [ Art .226 ]

S. 32 : Depreciation – ATM can be regarded as computer – Eligible depreciation at rate of 60 % .

S : 32: Depreciation – Intangible asset – Firm succeeded by Company – Revaluation of assets – Assessee is entitle to depreciation on actual cost incurred by it – 5th proviso will apply only in the year of succession and not in subsequent years and also in respect of over all quantum of depreciation in the year of succession – Order of Appellate Tribunal was quashed [ S.32 (1)(ii), 47(xiii) ]

S. 69A : Unexplained money – Search and seizure – Noting in diary of third party – Seized in the course of search – Without any corroborative evidence and had no authenticity, no additions could be made .[ S. 132 (4A) , 292C ]