S. 143(3) : Assessment- Overdue interest-Provisions for bad and doubtful debts – Schedule bank – Interest income on NPAs is taxable on receipt basis and not on accrual basis. [S.4,28(i), 36, 37 (1)]

S. 92C : Transfer pricing – Arms’ length price – Profit Split Method can be adopted as most appropriate method in cases involving multiple inter-related international transactions which cannot be evaluated separately.

S. 68: Cash credits – Mere non-production of directors of Creditor Company cannot justify addition when detailed evidences filed.

S. 68 : Cash credits – Bogus purchase – Liability pursuant to purchase and corresponding stock declared in books – No case of under assessment and no bogus liability to make addition[ S.143(3)]

S. 50C : Capital gains – Full value of consideration – Stamp valuation – Disputed valuation adopted by stamp duty authorities before AO – AO is required to refer the matter of valuation to Valuation Officer.[ S.45 ]

S. 37(1) : Business expenditure – Making charges paid to Goldsmiths allowable as the Assessee offered to tax the making charges collected from customers.

S. 36(1)(iii) : Interest on borrowed capital – Disallowance cannot be made as Assessee established that loan advanced at interest lower than interest paid on unsecured loans out of interest free funds.

S. 32 : Depreciation -Building – Partly used for business – Depreciation on Building is disallowable in proportion of let out to total constructed area of the building. [S. 38]

S. 14A : Disallowance of expenditure – Exempt income – Disallowance cannot exceed exempt income notwithstanding Assessee’s suo-motu disallowance is more than exempt income. [ R.8D ]

S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty – Distributor/reseller agreement and service agreement for support to end users and after sales services have to be read together to examine nature of income – Access to trademarks, intellectual property, technical knowhow, derivative works, brand features, confidential information, etc., while discharging its obligation under both agreements – Amount payable under distributor/reseller agreement was ‘Royalty’ -DTAA- India – Ireland . [S. 195, 201, Art. 12]