S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident– Interest – Royalty-Fes for technical services-DTAA-India-Switzerland. [S.9(1)(vi), 195, Art.14]

S. 37(1) : Business Expenditure–Advertisement expenses-Assessee not confronted with fact that notices to parties to whom expenses claimed to have been paid returned unserved-Matter Remanded–AO to decide afresh after confronting assessee and after hearing assessee.

S. 37(i) : Business Expenditure-Provisions for gratuity and leave encashment made with reasonable certainty on basis of independent actuarial valuation same is allowable. [S. 145]

S. 37(1) : Business expenditure-Not commenced business operations-lease rentals is allowed to be set off against lease rentals paid as well as excess expenditure allowable for capitalization.

S. 37(1) : Business expenditure-Accrual of liability-Payment of countervailing duty on imported goods-Claim to refund not a ground for treating liability as not accrued-Liability is held to be allowable as deduction. [S. 145]

S. 37(1) : Business expenditure-Self made vouchers-Ad hoc disallowance is not justified. [S. 145]

S. 37(1) : Business expenditure-CSR expenditure-Disallowance in lieu of Explanation 2 to Section 37(1)-No retrospective effect of Explanation 2-CSR Expenditure allowed.

S. 36(1)(va) : Any sum received from employees-Employees contribution to PF and ESI paid after the due date as per the relevant statutes but before filing of return of income under section 139(1) of the Act is not be disallowed.[S.43B, 139(1)]

S. 36(1)(iii) : Interest on borrowed capital-Interest paid to relatives and non-relatives-Difference between rate of interest charged by private money-lender and that charged by bank bound to exist-Assessee paying interest after deducting tax at source-AO failed to show that assessee utilised loan for purpose other than business-Interest expenses is held to be allowable.

S. 32 : Depreciation-On runway, isolation parking bay and roads, culverts and drains as buildings-Matter remanded for verification.