S.147: Reassessment – After the expiry of four years – Change of opinion- Interest income on fixed deposit assessed as business income – Re assessment on the ground that it has to be assessed as income from other sources. [S.56, 148, Art.226]

S. 115JB: Book profit – Provision for bad and doubtful debt – Ascertained liability – No addition can be made.

S. 80HHC : Export business – Entitle to deduction on gross total income without reducing it by the deduction allowed u/s 80IB of the Act .[ S. 80IA (9) , 80IB ]

S.37(1): Business expenditure – Volckar Committee Report- Commission paid to Iraqi Government agency for purchase of oil – Held to be allowable expenditure .

S. 37 (1): Business expenditure – Expenditure on temporary structure – Provision for deferred liability – Held to be allowable. [ S.115JB ]

S. 35DDA : Amortisation of expenditure – Voluntary retirement scheme – Entitled to claim deduction only to extent of 1/5th only during impugned assessment year against aggregate payment. [ S.147 ]

S. 10A : Free trade zone – New Industrial undertaking – Advance pricing agreement – (APA) -As per saving clause contained in S. 92CD(2), if an assessee is otherwise entitled to deduction u/s 10A, or for that matter under any other provision of the Act, in respect of the income offered in the modified return, the same cannot be denied. [ S.92CD(1) ]

S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services –Permanent usage of the service envisages by the concept of make available services remains at the disposal of their service recipients- Liable to be assessed as as FTS both under the Income Tax Act and under the tax treaty as well – DTAA -India -USA [ Art . 12(2) ]

Interpretation of taxing statutes-Judgements to be read .

Art : 141:Precedent – The judgment must be read as a whole and the observations from the judgment have to be considered in the light of the questions which were before this Court- Reassessment [ Income -tax Act ,1961 ,S.147 , 148 ]