Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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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