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    <title>2022 (12) TMI 571 - ITAT MUMBAI</title>
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    <description>The ITAT upheld the CIT(A)&#039;s decision, allowing the set off of franchise fees against brought forward business loss. It was determined that the franchise fee income, earned in the course of the appellant&#039;s business, was assessable as business income and eligible for set off, regardless of its classification as royalty income. The nature of income did not affect its eligibility for set off, as long as it was derived from the business or profession conducted by the assessee.</description>
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      <description>The ITAT upheld the CIT(A)&#039;s decision, allowing the set off of franchise fees against brought forward business loss. It was determined that the franchise fee income, earned in the course of the appellant&#039;s business, was assessable as business income and eligible for set off, regardless of its classification as royalty income. The nature of income did not affect its eligibility for set off, as long as it was derived from the business or profession conducted by the assessee.</description>
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