Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation 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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