S. 40(a)(ia) : Amounts not deductible-Deduction at source– Professional fees–Payment made outside India–Not chargeable to tax in India – Not liable to deduct tax at source-DTAA-India-China. [S. 9(1)(vii), 90(2), 195]

S. 40(a)(i) : Amounts not deductible-Deduction at source– Commission or brokerage–Manufacture of goods as per specification–No principal-Agent relation ship–Not liable to deduct tax at source-No disallowances can be made. [S. 194H].

S. 40(a)(i) : Amounts not deductible-Interest-Party residing outside India–Exemption from Ministry of Finance–Not liable to deduct tax at source. [S. 10(15)(f), 195]

S. 37(1) : Business expenditure–Capital or revenue–Different treatment in accounts and computation-Allowable as revenue expenditure. [S. 145]

S. 37(1) : Business expenditure–Legal expenses incurred to protect the directors for complaint filed against them in individual capacity –Not allowable as business expenditure.

S. 28(i) : Business loss-Shortage of goods –Running of show room-Franchise agreement-Payment made to the company–Loss is held to be allowable. [S. 37(i)]

S. 2(35) : Principal officer-Notice must mention some connection with the management or administration of the company–Merely on surmises and conjectures, no person shall be treated as a Principal officer. [Art. 226]

S. 2(14) : Capital asset–Advance given to subsidiary–Loss–Held to be allowable as short term capital loss. [S. 2(42A), 2(47)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue–Kuri business–Profit making activity-Not incidental to attainment of objects of trust-Revision is held to be valid. [S.2(15), 11(4), 12A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue–Long term capital gain-Information from DIT (Inv)–All relevant documents in relation to LTCG which reflected occurrence of transaction of sale of shares in normal course on platform of stock exchange-Revision is held to be not valid. [S.10(38), 45]