S. 36(1)(iii): Interest on borrowed capital — Amount used to assist sister concern — Interest not deductible.

S.32: Depreciation — Rate of depreciation —Hiring out construction Equipment —Crane depreciation allowable at 30% – It cannot be reduced to 15% – Res Judicata —Not strictly applicable but consistency essential.
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S.32: Depreciation —Uninterrupted power supply system for Computers —Entitled to depreciation at 60 Per Cent.

S. 14A : Disallowance of expenditure – Exempt income – Investment from borrowed capital – Presumption that advances made out of interest free funds- No facts pleaded for apportionment – Deletion of addition is held to be justified [S.36(1)(iii), R. 8D ]

S. 14A : Disallowance of expenditure – Exempt income – No expenditure was incurred – Disallowances cannot be made . [ R.8D ]

S. 12AA : Procedure for registration –Trust or institution- Order of Tribunal directing to grant registration is up held – If objects later found not genuine authority has option to cancel registration.[ S.2(15) 11, 12, 12A, Trust Act 1882 , Registration Act 1908 ]

S. 12A : Registration –Trust or institution- Statutory body for urban development under control of State Government is charitable institution entitled to registration. [ S.2(15),11 Rule 17A ]

S. 11 : Property held for charitable purposes – Depreciation – Allowable as deduction [ S.32 ]

S. 11 : Property held for charitable purposes – First proviso- Event of Garba organised to raise money — Amount earned entitled to exemption [ S.2(15), 12 ]

S. 9(1)(i): Income deemed to accrue or arise in India – Business connection – Non -resident – Goods for export -Amount received as demurrage charges from seller in India — Held to be not taxable [ S.5 (2)(b), 40(a)(i), 172 ]

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