Section 48 of the Income Tax Act

For attracting Section 14A disallowance, there must be a proximate cause relating the expenditure to actual tax-exempt income, and such disallowance is not automatic but requires positive material. Additionally, Section 94(7) on dividend stripping only ignores losses to the extent of dividend received for assessment years post-April 1, 2002, allowing the remaining loss.

A statute should not be construed to permit double deduction for the same expenditure unless specifically provided by law.

Income is taxable only when it represents real income, not notional income. It accrues only when there is a vested right to receive it, typically upon the occurrence of a transfer or event, rather than merely on a time basis.

A transfer of immovable property, for the purpose of capital gains under section 2(47)(v) of the Income-tax Act, occurs only when the agreement allowing possession in part performance of a contract is a registered instrument, as mandated by Section 53A of the Transfer of Property Act.

An act that is otherwise valid in law cannot be treated as non-existent or invalid merely because of an underlying motive to reduce tax liability or a perceived economic detriment to national interest; legitimate tax planning is permissible.

A receipt not chargeable as capital gains under Section 45 cannot be taxed under the residuary head of income from other sources (Section 56). If a receipt is not taxable under specific provisions, it cannot be brought to tax under any other section.

Income accrues when it becomes due, vesting the assessee with the right to claim the amount, even if payment is not immediate. It requires a corresponding liability from the other party to pay, emphasizing real rather than hypothetical accrual, particularly for assessees using the mercantile system of accounting.

Interest charged on delayed realization of sale proceeds constitutes business income and is eligible for deduction under Section 80-I of the Income-tax Act.

For capital assets acquired by gift or will, the indexed cost of acquisition under Section 48 is computed with reference to the year the previous owner first held the asset. The period of holding for determining if an asset is long-term also includes the previous owner's holding period, as per Section 2(42A).

The Supreme Court examined the validity of customs duty on newsprint in the context of Article 19(1)(a), emphasizing that the press advances public interest by publishing facts and opinions crucial for a democratic country.