Whether the profits earned by an assessee carrying on a priority industry which are assessable u/s.41(2) of the I.T.Act, 1961 can be treated as profits attributable to the priority industry and whether relief u/s.80-I (earlier section 80-E) of I.T.Act, 1961 can be allowed in respect of such profits.
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Priority industry income attribution determines eligibility for tax deduction; only operational receipts qualify for the deduction. Only income directly attributable to the carrying on of the business of a priority industry qualifies for the deduction under section 80-I; incidental or non-operational receipts such as proceeds from sale of redundant scrap or receipts from business sales or takeovers that are not integral to the core operations must be excluded from eligible profits.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Priority industry income attribution determines eligibility for tax deduction; only operational receipts qualify for the deduction.
Only income directly attributable to the carrying on of the business of a priority industry qualifies for the deduction under section 80-I; incidental or non-operational receipts such as proceeds from sale of redundant scrap or receipts from business sales or takeovers that are not integral to the core operations must be excluded from eligible profits.
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