S. 45 : Capital gains-Non-Resident-Sale of debt instruments in India-Certificate of Singapore Tax Authorities that income from foreign exchange transactions in India be taxable in Singapore-Entitled to exemption-DTAA-India-Singapore.[Art, 13(4), 24]

S. 44BB : Mineral oils-Computation-Presumptive tax-Non-resident-Service tax collected-Not includible in gross receipt. [S.44BB(2)]

S. 44BB : Mineral oils-Computation-Presumptive tax-Non-resident-Service tax collected-Not includible in gross receipt-SLP of Revenue is dismissed [S.44BB(2)]

S. 44 : Insurance business-Computation of profits-The rules contained in the First Schedule appended to the Act will determine the manner in which the profits and gains of insurance business are to be ascertained. [S.14, 28, 43B, 199]

S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-No evidence of cessation of Liability-Order of Tribunal is affirmed. [ S. 260A )

S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Liability is converted into loan and repaid-Deletion of addition is justified.

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Credit card processing fees-Not commission-Not liable to deduct tax at source.[S. 194H]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Real employer of seconded employees was Indian entity-Disallowance is not justified.[S. 192, 195]

S. 37(1) : Business expenditure-Capital or revenue-Software company-Expenditure on developing new product-New product abandoned as not feasible-Allowable as revenue expenditure.

S. 37(1) : Business expenditure-Licence fee-Allowable as deduction.