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    <title>2013 (10) TMI 542 - ITAT HYDERABAD</title>
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    <description>A statutory housing board with separate legal personality was held not to be the State Government for Article 289 purposes, so its income was taxable and not immune as government income. Statutory transfer of surplus after accrual was treated as application of income, not diversion by overriding title. A remittance for infrastructure facilities was disallowed as revenue expenditure because no sufficient business nexus was shown. Pension payments were allowed as revenue expenditure where the service liability was established. Estimation of profit from the Singapore project on a presumptive basis was rejected in the absence of rejection of regular books, and the matter, including section 80-IB consideration, was remitted for fresh adjudication.</description>
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      <link>https://www.taxtmi.com/caselaws?id=238087</link>
      <description>A statutory housing board with separate legal personality was held not to be the State Government for Article 289 purposes, so its income was taxable and not immune as government income. Statutory transfer of surplus after accrual was treated as application of income, not diversion by overriding title. A remittance for infrastructure facilities was disallowed as revenue expenditure because no sufficient business nexus was shown. Pension payments were allowed as revenue expenditure where the service liability was established. Estimation of profit from the Singapore project on a presumptive basis was rejected in the absence of rejection of regular books, and the matter, including section 80-IB consideration, was remitted for fresh adjudication.</description>
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