S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Fees for technical services-Reimbursement to non-resident AEs-Revenue unable to prove that payments are FTS-Disallowance deleted [S. 9(1)(vii), 195]

S.37(1): Business expenditure-Capital or revenue-Payments made by an assessee for the use of a logo or trademark for a particular period, aimed at business improvement/expansion, qualify as revenue expenditure.[S. 260A]

S. 37(1) : Business expenditure-Bogus expenses-Double taxation-Two constituent entities already offered to tax certain amounts out of receipts of aggregate amounts from assessee-Same amount not liable to be taxed in the hands of the assessee as it would amount to double taxation.[S. 260A]

S. 36(1)(vii) : Bad debt-It is sufficient for the debt to be written off as irrecoverable in the assessee’s accounts to be eligible for deduction, without the need to prove that the debt has actually become bad. [S. 36(2), 260A]

S. 36(1)(vii) : Bad debt-Payments made by a chit fund company to cover defaults by chit holders, ensuring the continuation of the chit cycle, can be treated as bad debts. [S. 260A]

S. 36(1)(va): Any sum received from employees-Employees’ contributions to PF and ESIC, made after the due date, was not allowable under section 36(1) (va) of the Income Tax Act-Delay of 690 days-No reasonable cause-Delay is not condoned [S. 253, 260A]

S. 9(1)(vi): Income deemed to accrue or arise in India-Royalty-Live sports telecast fees not royalty-No copyright in live feed-DTAA overrides domestic law-Income from live telecast is not assessable as royalty-DTAA-India-Singapore-Thailand [Copyright Act, 1957, 2(y), 13, Art. 3]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Scope of total income-Taxation of income from permanent establishment-Effect of article 7 of India-United Arab Emirates Double Taxation Avoidance Agreement-Global income or profit irrelevant and not determinative-Article 7 does not expand its gaze or reach to overall operations or profitability of transnational enterprise-Activities of permanent establishment liable to be independently evaluated and ascertained-Article 7 does not restrict right of source State to allocate or attribute income to permanent establishment based on global income earned or loss incurred by cross border entity-DTAA-India-United Arab Emirates [S. 5, Art. 7]

S. 4 : Charge of income-tax-Capital or revenue-Income-Exemption from excise duty not under the purview of definition of income envisaged under S. 2(24)(xviii)-Such amount is thus not an income but capital receipt, not taxable under the Act-Entries in books of accounts not conclusive to determine income-No tax can be charged on an amount not actually earned.[S. 2(24)(xviii), 145]

S. 2(47) : Transfer-Capital loss-Reduction of share capital-loss due to reduction in number of shares pursuant to the court order-Change in redeemable value of shares amounts to extinguishment of rights in shares-No Transfer Within Meaning Of Section 2(47) [S 45]