Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
The High Court held that the deduction u/s 33AC for creating a reserve to acquire new ships must be factored in while computing the deduction u/s 80-I, which is based on profits from operating ships. The amendment in 1996 capping the Section 33AC deduction at 50% of profits did not change the core character of the allowance. If the Section 33AC deduction results in no profits from ships, the Section 80-I deduction cannot be claimed. Regarding proportionate allocation of the Section 33AC deduction between qualifying and non-qualifying ships for Section 80-I purposes, the High Court stated that it cannot provide its own basis for apportionment as an appellate forum.
The High Court held that the deduction u/s 33AC for creating a reserve to acquire new ships must be factored in while computing the deduction u/s 80-I, which is based on profits from operating ships. The amendment in 1996 capping the Section 33AC deduction at 50% of profits did not change the core character of the allowance. If the Section 33AC deduction results in no profits from ships, the Section 80-I deduction cannot be claimed. Regarding proportionate allocation of the Section 33AC deduction between qualifying and non-qualifying ships for Section 80-I purposes, the High Court stated that it cannot provide its own basis for apportionment as an appellate forum.
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