Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
Rectification of mistake - period of limitation - To give appeal effect of orders passed by the ITAT and issue a refund. - The High Court referred to the interpretation of the term "received" and its implications, emphasizing that the limitation period should commence when the Department becomes aware of the order, not necessarily when the certified copy is physically received. - In light of the principles established in previous cases, including CIT v. Odeon Builders P. Ltd. and Lakhpatrai Agarwal v. CIT, the Court held that the Department's failure to comply with the ITAT's order within the stipulated time was unjustified.
Rectification of mistake - period of limitation - To give appeal effect of orders passed by the ITAT and issue a refund. - The High Court referred to the interpretation of the term "received" and its implications, emphasizing that the limitation period should commence when the Department becomes aware of the order, not necessarily when the certified copy is physically received. - In light of the principles established in previous cases, including CIT v. Odeon Builders P. Ltd. and Lakhpatrai Agarwal v. CIT, the Court held that the Department's failure to comply with the ITAT's order within the stipulated time was unjustified.
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