“Section 2(93)”

Interest income earned by an assessee during the period when its business has not commenced, even from funds meant for capital expenditure, is revenue in nature and is assessable under the head 'income from other sources'. The nature of the income, rather than the source of the funds generating it, determines its taxability.

The Assessing Officer cannot make a prima facie adjustment to the total income under Section 143(1)(a) if the adjustment involves a debatable issue.

A loan or advance from a closely held company to a 'concern' where a common shareholder has a substantial interest is not a deemed dividend under Section 2(22)(e) for the 'concern' if it is not a shareholder of the lending company. Deemed dividend under Section 2(22)(e) is taxable only in the hands of the registered or beneficial shareholder.

For the purpose of accumulation of income under section 11(1)(a), the calculation is to be made on the gross receipts of the trust before deducting any expenses. This interpretation is based on the plain language of section 11(1)(a) and is supported by Supreme Court decisions.

An assessment order directing the initiation of penalty proceedings under section 271(1)(c) is deemed to constitute the Assessing Officer's satisfaction for initiating penalty proceedings under section 271(1B). This applies even after amendments to the law.

The Court held that unless there is tangible material to believe that income has escaped assessment, reassessment proceedings cannot be initiated merely on a change of opinion by the Assessing Officer. The absence of independent material vitiates the reassessment.

Expenditure incurred by an assessee for a license to use software is eligible for revenue expenditure deduction under section 37(1) if it does not confer an enduring benefit on the assessee.