S. 41(1) : Profits chargeable to tax – Remission or cessation of trading liability -Sundry creditors – Produced details of court cases at Kuwait and correspondences with its overseas buyers/agents its efforts for making recovery to justify that these payments were still due from customers albeit same was produced before tribunal for first time—No justification in confirming additions.

S. 40(a)(ia) : Amounts not deductible-Deduction at source -Short deduction of deduction at source–No disallowance can be made. [S.194C, 194J, S. 201]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident -Marketing expenses—Payment made by assessee to foreign entities towards marketing and sale support services were not chargeable to tax in India and assessee was right in law in not deducting any tax thereon – DTAA-India –USA. [S. 195, Art .24(1)]

S. 37(1) : Business expenditure-Preliminary and preoperative expenses-Branch office at UAE-Existing business in UAE- Disallowance of expenditure is held to be not justified.

S. 37(1) : Business expenditure–Rural development expenses–Held to be allowable as business expenditure-Leave encashment scheme -Held to be allowable.

S. 37(1) : Business expenditure-Expenditure incurred by assessee for providing training to persons through Apparel Training & Development Centre in form of assistance of Rs. 2,000/- per trainee was in category of corporate social responsibility (CSR) was held not allowable unless and until expenditure was incurred wholly and exclusively for purpose of business of assessee.

S. 37(1) : Business expenditure -Designing and exhibition of player outfits —Held to be revenue expenditure.

S. 37(1) : Business expenditure -Security charges—visits of actors, celebrities and VIPs was part of strategic planning by assessee for generating higher revenues—Held to be allowable business expenditure.

S. 37(1) : Business expenditure–Coaching services–Held to be allowable as business expenditure.

S. 37(1) : Business expenditure -Security services for stadium—Payment of Rs. 75 lac was made by assessee to Kolkata Police Welfare fund, not by its choice, but as per directions of CAB who was responsible to arrange for security in stadium at time of staging of matches by assessee –Held to be allowable business expenditure.