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...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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The ITAT upheld the disallowance of deduction under Section 80IC for lease rental income earned by the assessee company, holding it lacked a direct nexus with the manufacturing activity at the eligible unit. Lease income was classified as "Other income" and not profits derived from the eligible undertaking, thus ineligible for deduction. The tribunal emphasized the distinction between income "derived from" and "attributable to" the business, rejecting claims for lease rental and interest income under Section 80IC. Project development income and liabilities written back were remanded to the AO for fresh verification to determine eligibility. Capital subsidy amortization was held ineligible as it affects profits through depreciation, not direct business receipts. Miscellaneous income was disallowed due to lack of evidence. The tribunal also concurred that deduction cannot be claimed for manufacturing activities outside the specified eligible unit.
The ITAT upheld the disallowance of deduction under Section 80IC for lease rental income earned by the assessee company, holding it lacked a direct nexus with the manufacturing activity at the eligible unit. Lease income was classified as "Other income" and not profits derived from the eligible undertaking, thus ineligible for deduction. The tribunal emphasized the distinction between income "derived from" and "attributable to" the business, rejecting claims for lease rental and interest income under Section 80IC. Project development income and liabilities written back were remanded to the AO for fresh verification to determine eligibility. Capital subsidy amortization was held ineligible as it affects profits through depreciation, not direct business receipts. Miscellaneous income was disallowed due to lack of evidence. The tribunal also concurred that deduction cannot be claimed for manufacturing activities outside the specified eligible unit.
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