https://www.taxtmi.com/caselaws?id=175557 Deduction under s. 80-I turned on whether various receipts were "derived from" an industrial undertaking. Duty drawback under s. 75(1) Customs Act and refunds from transporters/insurers were held to have a direct nexus with manufacturing operations and were includible in eligible profits; CIT(A) was upheld. Sale proceeds of import entitlements, CCS, and IPR reimbursements were traced to Government schemes rather than the undertaking, applying SC's "derived from" test, and were excluded; CIT(A) was reversed. Foreign exchange difference was remanded to the AO to determine whether it arose in the revenue field (then includible) or capital field (then excludible). Sales-tax refund was excluded for failure to discharge the onus of proving eligibility; AO restored. Addition from change in stock valuation was deleted since bona fide method change could not disturb opening stock; CIT(A) upheld. Revenue appeal partly allowed. en-us Fri, 03 Aug 2001 00:00:00 +0530 Tue, 06 Jan 2026 20:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=175557 Deduction under s. 80-I turned on whether various receipts were "derived from" an industrial undertaking. Duty drawback under s. 75(1) Customs Act and refunds from transporters/insurers were held to have a direct nexus with manufacturing operations and were includible in eligible profits; CIT(A) was upheld. Sale proceeds of import entitlements, CCS, and IPR reimbursements were traced to Government schemes rather than the undertaking, applying SC's "derived from" test, and were excluded; CIT(A) was reversed. Foreign exchange difference was remanded to the AO to determine whether it arose in the revenue field (then includible) or capital field (then excludible). Sales-tax refund was excluded for failure to discharge the onus of proving eligibility; AO restored. Addition from change in stock valuation was deleted since bona fide method change could not disturb opening stock; CIT(A) upheld. Revenue appeal partly allowed. Case-Laws Income Tax Fri, 03 Aug 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=175557