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    <title>2010 (6) TMI 378 - HIMACHAL PRADESH HIGH COURT</title>
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    <description>Freight or transport subsidy received under a Government scheme does not qualify as profits derived from an industrial undertaking for deduction under Section 80-IA of the Income-tax Act, 1961. The expression &quot;derived from&quot; was treated as narrower than &quot;attributable to&quot; and requiring a direct, immediate source of income. Because the subsidy originated in the scheme itself, and not in the undertaking&#039;s manufacturing activity, it was characterised as an incentive or reimbursement rather than operational profit. The subsidy was therefore excluded from deductible business profits, and the assessee was not entitled to the claimed deduction.</description>
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      <link>https://www.taxtmi.com/caselaws?id=202100</link>
      <description>Freight or transport subsidy received under a Government scheme does not qualify as profits derived from an industrial undertaking for deduction under Section 80-IA of the Income-tax Act, 1961. The expression &quot;derived from&quot; was treated as narrower than &quot;attributable to&quot; and requiring a direct, immediate source of income. Because the subsidy originated in the scheme itself, and not in the undertaking&#039;s manufacturing activity, it was characterised as an incentive or reimbursement rather than operational profit. The subsidy was therefore excluded from deductible business profits, and the assessee was not entitled to the claimed deduction.</description>
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