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

Expenditure that provides a commercial advantage of an enduring nature may still be classified as revenue expenditure if its purpose is to facilitate existing trading operations, improve business efficiency, or upgrade existing products, depending on the specific context and objective.

The Supreme Court held that discount on the issue of debentures is a deductible expenditure that can be spread proportionately over the period for which the debentures remain outstanding, rather than being claimed entirely in the year of issue. This treatment acknowledges the enduring benefit derived from the funds raised through debentures.

When computing profits of an eligible unit for tax incentives, profits attributable to marketing and R&D activities carried out outside the eligible unit should not be demarcated or excluded. The re-computation of deductions under tax holiday sections is justified only when there is an arrangement to earn more than ordinary profits.

For claiming weighted deduction under section 35(2AB), the existence of recognition for a Research and Development (R&D) Centre is relevant, not necessarily the date of approval or recognition.

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

A mere substantial profit does not inherently indicate an arrangement to earn profits beyond ordinary levels to abuse tax concessions under Section 80-IA(9) or (10). The Assessing Officer must provide specific evidence of such an arrangement.

The Tribunal has comprehensive jurisdiction to deal with issues in an appeal and can allow a new ground to be raised, assimilating issues from the CIT (Appeals) order.