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    <title>2010 (1) TMI 1186 - ITAT DELHI</title>
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    <description>Deduction under section 36(1)(viia) is to be computed on total income before Chapter VI-A deductions, so the deduction under section 36(1)(viii) could not be ignored in fixing the base; this point went against the assessee. Deduction under section 36(1)(viii) was confined to profits directly derived from eligible long-term finance, so receipts such as interest on deposits, lease rentals, consultancy and other charges, dividends, sale gains, miscellaneous income and similar ancillary items were excluded; the debatable treatment of interest on debentures required factual verification and was remitted. The bad-debt disallowance under the interaction of sections 36(1)(vii) and 36(1)(viia) was not sustainable in full, and was therefore allowed only in part.</description>
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      <title>2010 (1) TMI 1186 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=180572</link>
      <description>Deduction under section 36(1)(viia) is to be computed on total income before Chapter VI-A deductions, so the deduction under section 36(1)(viii) could not be ignored in fixing the base; this point went against the assessee. Deduction under section 36(1)(viii) was confined to profits directly derived from eligible long-term finance, so receipts such as interest on deposits, lease rentals, consultancy and other charges, dividends, sale gains, miscellaneous income and similar ancillary items were excluded; the debatable treatment of interest on debentures required factual verification and was remitted. The bad-debt disallowance under the interaction of sections 36(1)(vii) and 36(1)(viia) was not sustainable in full, and was therefore allowed only in part.</description>
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