“Section 31(1)(iii)”

Expenditure incurred for commercial expediency, even without a direct or immediate benefit but indirectly facilitating business, is deductible as laid out wholly and exclusively for trade. The scope of reference jurisdiction under Section 66 is limited to questions of law, allowing challenges to Tribunal findings of fact only if they are perverse, unreasonable, or lack evidence.

The rule of consistency requires that in the absence of any change in material facts or law, a different view or decision on an issue cannot be adopted for subsequent assessment years, thus ensuring uniformity in tax assessments.

The Assessing Officer is bound by the rule of consistency and cannot take a contrary or different stand on an issue in a subsequent assessment year if the factual position remains identical to previous years where a deduction was allowed.

Interest paid on money borrowed for acquiring machinery is deductible under Section 36(1)(iii) even if the machinery is not put to use in the year of borrowing. This principle applies to the 'for the purpose of business' test for borrowed capital.

The annual letting value of properties that are not residential units, such as farm lands without any constructed residential unit, cannot be determined under section 22 of the Income Tax Act.

Once depreciation on an asset is allowed in the first year, the revenue is debarred from denying depreciation on the written-down value carried forward in subsequent years, absent a change in facts or law.