Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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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