S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Sundry creditors-Burden is on Revenue-Order of CIT(A) is affirmed.

S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Hived off its hire purchase and leasing business to a special purpose vehicle (SPV)-Assigned corresponding receivables together with bank liabilities to SPV at book-Liable to repay-Not chargeable to tax-Bank claimed as bad debt-No outstanding due from Bank in the books of account-Addition cannot be made. [S. 145]

S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits-Civil contractor-Material purchase and labour payments-Payment in excess of Rs. 20,000-Failure to prove exception-Disallowance is justified. [S. 263, R. 6DD]

S. 40A(2) : Expenses or payments not deductible-Excessive or unreasonable-Addition was deleted by CIT(A) in earlier year-Revenue has not challenged the order of earlier year-Addition was deleted. [S. 254(1)

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Contribution to Turf Authorities of India for conducting an event-Meet expenditure-Not liable to deduct tax at source-Subsidies to promote horse racing-Failure to mention which section of TDS provision is applicable-Addition was deleted.

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Advertisement services-Payment to Irish company-No Permanent Establishment in India-Not liable to deduct tax at source-DTAA-India-Irish. [S. 9(1)(i), 195, Art. 7]

S. 37(1) : Business expenditure-Carrying on of business-No business activities during the year-Matter remanded.

S. 37(1) : Business expenditure-Loss on account of exchange difference-Allowable as deduction. [S. 28(i)]

S. 37(1) : Business expenditure-Pre-operative expenses-Capital or revenue-Business of hotels, motels, catering etc.-Setting up business-Salaries and allowances to experts-Allowable as business expenditure.