Attributable to business income includes balancing charge on machinery sale for priority-industry deduction.

The expression "attributable to" was treated as wider than "derived from", so balancing charge under section 41(2) on sale of machinery used in a priority-industry business was included in the profits and gains attributable to that business. On that construction, the machinery-sale income was not excluded merely because it arose on sale of old machinery and qualified for deduction under section 80E(1).

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Issues: Whether the balancing charge arising under section 41(2) on sale of machinery used in the assessee's priority-industry business was part of the profits and gains attributable to that business for deduction under section 80E(1).

Analysis: The expression "attributable to" was treated as of wider import than "derived from". On that construction, the balancing charge arising from sale of old machinery forms part of the profits and gains attributable to the business of the priority industry, and the income under section 41(2) cannot be excluded merely because it arose on sale of machinery.

Conclusion: The machinery-sale income under section 41(2) was attributable to the assessee's priority-industry business and qualified for the deduction.

Ratio Decidendi: The phrase "attributable to" includes balancing charge arising from the sale of old machinery, and such income is part of the profits and gains attributable to the business of the specified or priority industry.

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