Chapter deductions and market value rules limit double claims, overlapping benefits, and transfer-based profit manipulation. Chapter-based deductions in computing total income are allowed from gross total income only in accordance with the governing provisions, and the aggregate deduction cannot exceed gross total income. The provisions prevent double deduction where an AOP or BOI has already claimed a deduction and members seek the same deduction on their share of income, and they also bar repeated deduction of the same profits under more than one eligible provision. For eligible businesses, the deduction is confined to the actual profits and gains of the undertaking, unit, enterprise or business. For inter-business transfers within the same assessee, profits are to be computed on the basis of market value where recorded consideration does not reflect market value.
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Provisions expressly mentioned in the judgment/order text.
Chapter deductions and market value rules limit double claims, overlapping benefits, and transfer-based profit manipulation.
Chapter-based deductions in computing total income are allowed from gross total income only in accordance with the governing provisions, and the aggregate deduction cannot exceed gross total income. The provisions prevent double deduction where an AOP or BOI has already claimed a deduction and members seek the same deduction on their share of income, and they also bar repeated deduction of the same profits under more than one eligible provision. For eligible businesses, the deduction is confined to the actual profits and gains of the undertaking, unit, enterprise or business. For inter-business transfers within the same assessee, profits are to be computed on the basis of market value where recorded consideration does not reflect market value.
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