Section 42 of the Income Tax Act

The retrospective insertion of an Explanation to Section 80IB(9) of the Income Tax Act is unconstitutional. Blocks licensed under a single contract cannot be treated as a single undertaking for the purpose of deduction under Section 80IB(9).

The Production Sharing Contract (PSC) is a self-contained code. Provisions of the Income-tax Act apply to the computation of income of the assessee under the PSC. Overhead charges incurred by the head office and charged to the assessee's profit and loss account are allowable as a deduction if incurred for the purpose of business.

The Assessing Officer must record reasons for not being satisfied with a suo motu disallowance made by an assessee under section 14A, and this satisfaction must be based on the assessee's accounts.

Cranes do not fall within the ambit of commercial vehicles, motor lorries, or motor taxis for the purpose of claiming depreciation at a 30% rate.

The case recognizes the evolving landscape of international business operations and the role of holding companies in ensuring adherence to global standards by subsidiary entities to protect brand value.

An expenditure not allowed as a specific deduction can still be considered an allowable business loss under the general principles of income computation, even if a specific condition for that deduction was not met.

Service of notice of scrutiny assessment under Section 143(3) is mandatory, and without valid service, the assessment order is void.

Section 42 of the Income-tax Act allows deductions specified in an agreement between the assessee and the Central Government. Expenses incurred for business activities may be allowed as business expenditure even if not specifically deductible under Section 42.

Reopening of assessment is impermissible if the issue sought to be reopened was already considered and decided in a regular assessment under section 143(3), particularly if the subsequent reopening is based on a mere change of opinion.