S. 36(1)(iii) : Interest on borrowed capital – Capital was borrowed for acquisition of fixed assets and only a part of assets were put to use- Interest was to be allowed only to the extent the assets were operational during the current year.

S. 36(1)(iii):Interest on borrowed capital-Finance Charges- Not deductible as these expenses were not relatable to the main business activity of the assessee. [S. 57(iii)]

S. 36(1)(ii) : Interest on borrowed capital- Utilized for purchase of shares- Allowable as deduction.

S.28(i): Business income- Agricultural income – Where the agricultural activities were carried out by the farmers mere supervision by the Assessee without carrying basic operation would not qualify as agricultural activities and accordingly income of the Assessee from processing, packing and sale of various seeds procured from farmers was liable to be treated as business income and not agricultural income [ S.10(1) ]

S. 35D : Amortization of preliminary expenses – Fees paid for increasing the authorize share capital of the assessee company which has been registered in an earlier year is not allowable as a preliminary expense [S. 40(a)(ia) , 194J]

S. 32 : Depreciation- Computer peripherals-Eligible higher rate of depreciation .

S. 32 : Depreciation- Non compete fee- Depreciation is held to be not allowable .

S. 28(i) : Business income- In terms of memorandum of association, main object of assessee company was to acquire properties and to further let out such properties, income earned from such letting out was to be brought to tax as ‘business income’ and not as ‘income from house property’ [ S. 22, 27(iiib), 269UA(f) ]

S.14A: Disallowance of expenditure – Exempt income – There was no exempt income earned and interest expense was not related to strategic investments of the company- Disallowance is not justified . [ R.8D ]

S. 14A : Disallowance of expenditure – Exempt income – Disallowance cannot made as without bringing basic fact that expenditure actually incurred to earn exempt income- Matter remanded to the AO. [ R.8D( 2) (ii) ]