Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
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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