The Tribunal held that payments made by the assessee to various entities were for contractual work and not for professional or technical services. Therefore, tax was correctly deducted under Section 194C of the Income-tax Act, 1961, with no additional liability under Section 194J. The Revenue's appeal was dismissed.

The appeals were dismissed due to the tax effect being below the monetary limit set by the CBDT Circular. The Tribunal ruled in favor of the assessee on various issues, including TDS on deemed service tax and payments for telecasting short films. Interest was to be charged from the date TDS was deductible to the date of filing the return by deductees. The Tribunal directed a re-evaluation of payments for instruments, documentary films, AMC contracts, and financial assistance, emphasizing the need for detailed orders. The revenue's appeals were dismissed, and the assessee's appeals were allowed for statistical purposes.

The Tribunal allowed both appeals for statistical purposes, remitting certain issues back to the AO for fresh examination. Key determinations included: discounts to walk-in patients not requiring TDS, pending verification of TDS on hospital commissions; the nature of the relationship with hospitals/laboratories requiring further scrutiny; and routine maintenance charges falling under Section 194C, not Section 194J, as per CBDT guidelines and case law.

The Tribunal ruled in favor of the assessee regarding the non-deduction of TDS on uniform items, stitching charges, washing expenses, and CMRE payments, dismissing the Revenue's appeals on these issues. However, in the classification of payments for hiring equipment and vehicles, the Tribunal partly allowed the Revenue's appeal for seismic job services and short holes, but upheld the CIT(A)'s decision for AMC contracts and vehicle hire charges. The Tribunal instructed the AO to re-calculate the liability after allowing the assessee to provide additional details.

The Tribunal ruled in favor of the appellant, directing the Assessing Officer to reassess the treatment of receipts from software licensing, sale of hardware, support services, and amounts recovered from a specific entity. The Tribunal emphasized that software sales should not be classified as royalty, hardware sales are not royalty, support services do not qualify as Fees for Technical Services (FTS), and reimbursements should be scrutinized for FTS classification. Additionally, the Tribunal instructed that no interest under section 234B of the Income Tax Act should be imposed on the appellant.

The Tribunal partially allowed the appeals, ruling that receipts from the sale of hardware with embedded software and software receipts were not taxable as royalty. The issue of reimbursements was remanded for further assessment, with directions to grant credit for TDS and apply the correct surcharge rate. The Tribunal also decided against levying interest under section 234B and dismissed the penalty proceedings initiation.

The HC upheld that EDC payments to HSVP fall under Section 194C of the Income Tax Act, mandating tax deduction at source. It rejected the exemption claim under Section 196, as HSVP is not a Central Act corporation. The court found show cause notices vague but did not quash them. Penalty imposition requires assessing the petitioners' reasonable cause for non-deduction, with proceedings to be revisited accordingly.

The HC upheld the applicability of Section 194C of the IT Act, 1961, to EDC payments, rejecting the exemption claim under Section 196. Show cause notices, though vague, were not quashed as petitioners had the opportunity to present their case. The Court directed respondents to verify if EDC payments were taxed in HSVP's hands and to conclude pending proceedings, considering the petitioners' liability and potential penalties under Sections 201, 221, and 271C. Penalties are not automatic and depend on whether petitioners had valid reasons for not deducting tax. The Court allowed the continuation of proceedings based on these observations.

The Tribunal partly allowed the assessee's appeal and dismissed the revenue's appeal, upholding the directions of the Dispute Resolution Panel on various issues. The Tribunal directed the Assessing Officer to re-examine and correct errors in the computation of margins of comparables, reconsider the interest rate adjustment on external commercial borrowings, allow deductions for production costs, legal and professional expenses, and depreciation on IT & T expenditure, exploration costs, and tax credits. The Tribunal also instructed the AO to recompute interest under sections 234B of the Act and review an additional ground raised by the assessee.

The court held that credit for income tax paid in a foreign country in relation to income under Section 10A is not available under Section 90(1)(a). Unavailed MODVAT credit cannot be considered as income under Section 2(24). Commission paid to directors should be allocated to the units they head. AMC profits related to computers manufactured by the assessee are eligible for deduction under Section 80IB. VAT and GST collected in foreign jurisdictions should be included in export turnover. Capital gains on stock-in-trade conversion should be recognized when sold. Deduction under Section 10A for foreign exchange yet to be received is allowed. Software sales to STP units should be excluded from export turnover. Corporate expenses allocated at 20%. Expenses allocation based on actual expenditure. Units approved by STPI are eligible for deduction under Section 10A. Losses of 10A units carried forward. Various incomes included under Section 80HHC. Certain incomes exempted under Section 10A. Provision for warranty claims allowable. Non-deduction of TDS for software imports not disallowed. Excise duty and sales tax included in total turnover under Section 80HHC. Telecommunication expenses exclusion remanded. Prior period items question deleted. Interest levy under Section 234D remanded. Termination expenses not substantial question of law. Taxability of interest under Section 244A remanded for calculation.

The Tribunal remanded various issues to the Transfer Pricing Officer for re-examination, emphasizing the need for thorough consideration of global transfer pricing policies and additional evidence. The Tribunal also directed the Assessing Officer to follow specific guidelines and allowed the appeal in part for statistical purposes.

The Tribunal upheld the CIT(A)'s decisions in various issues, including vacating the allocation of corporate expenses to s. 10A units due to lack of prescribed method, confirming that certain incomes should not be excluded from export turnover for s. 10A deduction, and directing the exclusion of specific items for s. 80HHC deduction. Additionally, the Tribunal clarified that deemed exports are not part of export turnover for s. 10A deduction and disallowed deduction under s. 80-IB for AMC receipts and sale of monitors. Foreign taxes were held not to be included in export turnover, and long-term capital loss on shares and interest under s. 234B and 234D were allowed and charged, respectively.