S. 37(1) : Business expenditure-Capital or revenue-Expenses incurred for upgradation of computers and to acquire software-Held to be revenue expenditure.

S. 36(1)(viii) : Eligible business-Special reserve-Financial Corporation-Entitled to deduction. [Companies Act, 1956. S. 3, 617]

S. 36(1)(iii) : Interest on borrowed capital-Amount advanced to sister concern without charging interest-Business purpose-Held to be allowable.

S. 36(1)(iii) : Interest on borrowed capital Sufficient surpluses and reserves-No disallowance of interest can be made.

S. 32 : Depreciation-Hotel-Additional floor space index granted-One instalment paid and entire amount debited in accounts-Entitled to depreciation on entire amount at rate applicable to buildings. [S. 32(1)(ii), 43(6)(c)]

S. 14A : Disallowance of expenditure-Exempt income-Tribunal justified in deleting the addition made by the Assessing Office. [s. 10(38), R. 8D]

S. 14A : Disallowance of expenditure-Exempt income-Onus to establish such proximity on department-Assessing Officer must give a clear finding with reference to the assessee’s accounts how expenditure related to exempt income. [S. 10(35), R. 8D]

S. 14A : Disallowance of expenditure-Exempt income-Failure by Assessing Officer to record dissatisfaction-No disallowance could be made. [R. 8D]

S. 14A : Disallowance of expenditure-Exempt income-Disallowance cannot exceed exempt income earned. [R. 8D]

S. 11 : Property held for charitable purposes-Statutory Board under control of State Government-Entitled to exemption. [S. 2(15)]