S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident–Independent personal services outside India-Not chargeable to tax in India –Not liable to deduct tax at source-DTAA–India–Canada. [S.9(1)(i), Art. 12, 14 ]

S. 37(1) : Business expenditure – Corporate social responsibilities- Held to be allowable – Explanation 2 inserted in section 37(1) with effect from 1-4-2015 is prospective in nature. [S. 35AC, 80G, Companies Act, 2013, S. 135]

S. 14A : Disallowance of expenditure-Exempt income–Stock in trade–Dividend received incidentally–No disallowance can be made. [R. 8D]

S. 11 : Property held for charitable purposes–kalyanamandapams, school, health centre and library-Donation to Trust–Predominant activity of assessee society is charity- Eligible for exemption. [S. 11(1), 11(4), 12A]

S. 10(23C) : Educational institution-Skill training programme– Placement activities-Entitle to exemption. [S. 2(15), 10(23C)(iiiab), 12AA]

S. 250 : Appeal-Commissioner (Appeals)–Additional evidence-Ex parte order- Duty of the CIT(A) to admit additional evidence in the interest of justice-Matter remanded to AO. [S.10AA, 80IC, 144, R. 46A(4)]

S. 143(3) : Assessment—Difference in form 26AS-Matter remanded. [26AS]

S. 9C : Transfer pricing—Functionally Different-Cannot be considered for comparable.

S. 92C : Transfer pricing-TNMM- Once a comparable was found functionally similar and further authentic and reliable financial data were available relevant to accounting period of assessee then merely comparable had different FY, it could not be excluded- TP adjustment made on outstanding receivable beyond 30 days credit period applying interest rate of 14.88% p.a. and computing interest receivable is held to be justified.

S. 92C : Transfer pricing-Arms length price-Items like spares, accessories, batteries are used by assessee in discharge its obligation of warranty or replacement of damaged items in transportation then no transfer pricing adjustment required to be made in respect of Purchase of finished goods and spares.