S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits-Failure to verify relevant documents-Matter remanded. [R. 6DD]

S. 40(a)(ia) : Amounts not deductible-Software purchase-Not royalty-Not liable to deduct tax at source [S.9(1), (vi), 195, 201(1), 201(IA)]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Commission-Agents residing outside India-Not liable to deduct tax at source.[S. 9(1)(i), OECD Model Tax Convention, Art. 7]

S. 37(1) : Business expenditure-Non-compete fees-Paid to individuals who had experience in business of consultancy for not to engage themselves in similar kind of business activities for a period of 3 years, such consideration was independent and not part of cost of acquisition of business, such fee was to be allowed as revenue expenditure.

S. 37(1) : Business expenditure-Foreign exchange loss-neither speculative loss within meaning of s.43(5), nor same was notional or contingent in nature, same being loss on foreign exchange derivatives allowed. [S.43 (5)]

S. 37(1) : Business expenditure-Factory shifting expenditure-Transportation expenditure from one site to another site, did not give any enduring benefit, same could not be treated as capital in nature.

S. 37(1) : Business expenditure-Commission-AO failed to considered the letter submitted by recipient wherein confirmed that entire commission paid was for relevant assessment year, matter needs remanded for consideration. [S.254(1)]

S. 37(1) : Business expenditure-Penal in nature-Contributed 15 per cent of sale proceeds to SPV account, these payment did not fall under category of penalty-Allowable as deduction. [Explanation 1 to section 37 (1)]

S. 36(1)(iii) : Interest on borrowed capital-Acquisition of capital asset is not an extension of existing business-Advance less than available free funds-Interest cannot be disallowed. [S. 37(1)]

S. 28(iv) : Business income-Value of any benefit or perquisites-Forfeiture of advance money-Benefit or perquisite arising from the business shall not be in monetary form-Not taxable-Amount would go to reduce the cost of property. [S. 51]