S. 37(1) : Business expenditure-The principle of commercial expediency cannot be ignored and must be judged in the context of current socio-economic thinking-Transfer Pricing-Objections raised by Dispute Resolution Panel met by assessee with cogent reasons-Transfer pricing adjustment is not called for. [S. 92C]

S. 32 : Depreciation-Rate of depreciation-Computer accessories and peripherals-Entitled to depreciation at higher rate applicable to computers.

S. 28(i) : Business income-Value of any benefit or perquisites-Converted in to money or not-Profits chargeable to tax-Remission or cessation of trading liability-Settlement of borrowings at lower amount than due-Constitutes waiver of loan-Borrowing and lending not business of assessee-No trading liability-No benefit or perquisite other than in shape of money-Difference between amount due and amount of settlement is not taxable. [S. 28(iv), 41(1)]

S .14A: Disallowance of expenditure-Exempt income-No dividend income received during year and no exemption claimed-Disallowance not sustainable-Amendment by Finance Act, 2022 . R.8D ]

S. 14A : Disallowance of expenditure-Exempt income-No satisfaction is recorded-Disallowance not sustainable. [ R.8D ]

S. 12AB: Procedure for fresh registration-Remanded to Commissioner (E) to allow assessee to file requisite details of activities undertaken including audited accounts for financial years 2020-21 and 2021-22 and decide application a fresh.

S. 10B: Export oriented undertakings-Senior management salaries had been allocated in ratio of turnover of export-oriented units and other units.

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Residuary article-Reimbursement of software licence fees-Absence of Permanent Establishment not taxable in India-DTAA-India-United States of America. [S.56 , 115A , art. 7, 12, 23(3) ]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-No material on record to demonstrate that assessee made available technical knowledge, skill, experience and know-h ow-Commissioner (Appeals) attributing 50 Per Cent. of receipts to consultancy services based on estimate and without any reasonable basis-Addition not sustainable-DTAA-India-UK [ art. 12(3)(b), 13(4) (c ) ]

S. 9(1)(vi): Income deemed to accrue or arise in India-Royalty-Providing online technology learning platform on its website-Subscription fee is not consideration for use or right to use any industrial, commercial or scientific equipment-Subscription revenue received is not taxable as royalty–DTAA-India-USA [art. 12(3) ]