Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
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Interest earned on fixed deposits compulsorily created under subsidy sanction conditions for a cold chain facility was held to have a direct nexus with the business activity, not to be income from other sources. On that basis, the Tribunal treated the interest as business income and held it eligible for deduction under section 80IB(11), deleting the disallowance. It also found the additions for savings bank interest and income-tax refund interest factually unsustainable, as no savings account existed in the assessee's name and no deduction had been claimed for refund interest. Those additions were deleted, and the appeal was allowed.
Interest earned on fixed deposits compulsorily created under subsidy sanction conditions for a cold chain facility was held to have a direct nexus with the business activity, not to be income from other sources. On that basis, the Tribunal treated the interest as business income and held it eligible for deduction under section 80IB(11), deleting the disallowance. It also found the additions for savings bank interest and income-tax refund interest factually unsustainable, as no savings account existed in the assessee's name and no deduction had been claimed for refund interest. Those additions were deleted, and the appeal was allowed.
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