S. 40(a)(ia) : Amounts not deductible-Deduction at source-Paid to Non-Resident for technical services-Amount neither debited to profit and loss account nor claimed as deduction-No disallowance can be made. [S. 37(1), 145]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Non-Residents-Payments were made outside India-Not liable to deduct tax at source.

S. 37(1) : Business expenditure-Loss in hedging contracts with Foreign Exchange dealers and banks-Not speculative allowable as business expenditure. [S. 28(i), 43(5)]

S. 36(1)(vii) : Bad debt-Amounts written off in accounts-Not necessary to prove that amount had become irrecoverable.

S. 37(1) : Business expenditure-Capital or revenue-Expenditure on software-Allowable as revenue expenditure.

S. 35D : Amortisation of preliminary expenses-Premium collected on issued share capital-Not part of capital employed-includible in preliminary expenses for amortisation-Cost of acquisition of companies does not form part of project expenses-Deduction to be distributed in subsequent years. [S. 37(1)]

S. 28(i) : Business loss-Bad debt-No evidence that loss was connected with business-Disallowance of loss is justified. [S. 36(1)(vii), 260A]

S. 28(i) : Business Loss-Loss in stock-in-trade-Allowable as business loss.

S. 14A : Disallowance of expenditure-Exempt income-Not earned any exempt income-Amendment providing for disallowance even if assessee has not earned exempt income is not retrospective-Precedent-Special Leave petition pending before Supreme Court but order of court not stayed-Binding on Tribunal-Interpretation of taxing statutes-Provision for removal of doubts cannot be presumed to be retrospective if it alters or changes Law as it stood. [R. 8D]

S. 11 : Property held for charitable purposes–Activities charitable in nature-Remanding matter-No substantial question of law. [S. 2(15), 12AA, 260A]