“Section 4(3)(ia)”

When an assessee's income is estimated after rejecting their books of account, further additions or disallowances for specific expenses are generally not permissible, as the estimation already accounts for these.

A taxpayer is eligible for deduction under Section 80IA for developing and operating infrastructure facilities, with the decision clarifying the distinction between a contractor and a developer for this purpose.

Where an assessee invests its own funds in an infrastructure development project, it is presumed to be acting as a developer, not merely a contractor, making it eligible for deduction under section 80-IA(4).

Prior to the jurisdictional High Court's decision in CIT v. Samsung Electronics Co. Ltd. on October 15, 2011, the purchase of off-the-shelf software was not subject to TDS, and therefore, no disallowance under Section 40(a)(i) or 40(a)(ia) could be made.

When business income is estimated, disallowances under Section 40A(3) for cash payments and Section 40(a)(ia) for non-deduction of TDS should not be made.

Payments for services are not taxable as fees for technical services (FTS) under a Double Taxation Avoidance Agreement (DTAA) if the services do not 'make available' any technical knowledge, know-how, or expertise to the recipient in India.

Expenses incurred in connection with a public issue of shares or debentures are allowable as revenue expenditure eligible for deduction under section 35D of the Income-tax Act. This includes expenses related to Qualified Institutional Buyers (QIBs).

Contracts involving development, operation, maintenance, financial involvement, and defect correction are eligible for deduction under section 80-IA(4), even when allotted by government bodies. Such contracts are not considered simple works contracts for the purpose of denying this deduction.