Section 43B(f) of the Income Tax Act

The Calcutta High Court held that restricting deduction for leave encashment via Section 43B(f) was arbitrary and contrary to Supreme Court decisions. However, this judgment was later stayed by the Supreme Court.

When an assessee has both borrowed funds and sufficient interest-free own funds, and makes interest-free advances, it is presumed that the advances were made from the own funds, and no interest disallowance is made under Section 36(1)(iii) on the borrowed funds.

Income that accrues or arises abroad is not deemed to accrue or arise in India, even if there is a business connection in India, clarifying the scope of taxability for non-residents.

A non-compete fee is an eligible business or commercial right for depreciation under Section 32(1)(ii) of the Income Tax Act, 1961, similar to copyrights and patents.

The provided passages only cite CIT v. Angelique International Ltd. as a precedent without detailing the specific legal proposition it stands for. Therefore, the holding cannot be determined from this information alone.

For the provisions of Section 43B to apply, not only must a liability to pay tax or duty be incurred in the accounting year, but the amount must also be statutorily "payable" in that year. A deduction is allowable for liabilities that have accrued but not yet become payable under the relevant law.

The Assessing Officer must first accept the arm's length price (ALP) declared by the assessee for international transactions with associated enterprises. Rejection of the declared ALP is an exception, requiring specific conditions to be met, such as those prescribed under section 92CA(3).

A revised return can only be filed under Section 139(5) if there is an omission or a wrong statement in the original return due to bona fide inadvertence or mistake.

The court considers the addition made in the hands of the assessee as business income based on advertisement and subscription revenue.

Software expenses are revenue in nature and allowable as business expenses, particularly when following established judicial precedents and principles laid down by Special Benches of the Tribunal.