Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
Notional carry forward of depreciation losses that were previously set off against other income cannot be notionally brought forward to compute the deduction under section 80IA, because section 80IA(5) contains no mandate for such notional setoff; consequence: such earlier-absorbed losses are excluded when computing the 80IA deduction. Separately, section 80IA(9) prevents double claiming of deductions so that deductions under other Chapter VIA provisions remain computable but their combined allowability with 80IA is capped at 100% of business profits; CBDT guidance supports this limiting effect to prevent repeated deductions.
Notional carry forward of depreciation losses that were previously set off against other income cannot be notionally brought forward to compute the deduction under section 80IA, because section 80IA(5) contains no mandate for such notional setoff; consequence: such earlier-absorbed losses are excluded when computing the 80IA deduction. Separately, section 80IA(9) prevents double claiming of deductions so that deductions under other Chapter VIA provisions remain computable but their combined allowability with 80IA is capped at 100% of business profits; CBDT guidance supports this limiting effect to prevent repeated deductions.
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