Section 35(1)(i) of the Income Tax Act

Membership rights and business contracts, as 'business or commercial rights of similar nature' to a license or franchise, qualify as intangible assets eligible for depreciation under Section 32(1)(ii) of the Income-tax Act.

Business contracts and commercial rights of similar nature qualify as intangible assets under Section 32(1)(ii) and are eligible for depreciation. The decision also affirms that goodwill is an intangible asset eligible for depreciation.

Expenditure on application software, which enhances business efficiency and requires a computer system to function, constitutes revenue expenditure rather than acquisition of a capital asset, even if it provides an enduring benefit.

The approval of an in-house R&D centre through Form 3CM is the primary document for claiming weighted deduction under Section 35(2AB) for scientific research expenditure. The case clarifies the significance of this form and the role of the prescribed authority (DSIR) in the approval process.

Disallowance under Section 14A cannot be made if the assessee has not received any exempt income during the relevant assessment year. The mere possibility of earning exempt income does not trigger disallowance.

The first appellate authority cannot dismiss an appeal for default without disposing of the grounds on merits. Dismissal without going into the merits is not justified.

AMP expenditure is not an international transaction. The Bright Line Test is not a valid basis for determining the existence of an international transaction or computing the arm's length price.

Disallowance under Section 14A cannot be added back when computing book profit under Section 115JB, as Section 115JB is a complete code in itself.

The Assessing Officer has reason to believe that income has escaped assessment when there is material on record, such as from a survey or a statement, indicating that the assessee has wrongly claimed a deduction.