https://www.taxtmi.com/caselaws?id=448788 ITAT Delhi held that disallowance u/s 14A r.w. Rule 8D was improper where investments were made from surplus funds rather than borrowed funds, following SC precedent in South Indian Bank Ltd. AO's failure to record satisfaction u/s 14A(2) constituted legal infirmity. Court allowed deduction u/s 80IB on scrap sales from manufacturing activity, citing Delhi HC decision in Sadhu Forging Ltd. CENVAT credit refund treated as capital receipt not includible in book profit u/s 115JB. Export incentives and other income allowed as part of eligible profits for 80IB deduction. en-us Thu, 25 Jan 2024 00:00:00 +0530 Tue, 30 Jan 2024 08:51:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448788 ITAT Delhi held that disallowance u/s 14A r.w. Rule 8D was improper where investments were made from surplus funds rather than borrowed funds, following SC precedent in South Indian Bank Ltd. AO's failure to record satisfaction u/s 14A(2) constituted legal infirmity. Court allowed deduction u/s 80IB on scrap sales from manufacturing activity, citing Delhi HC decision in Sadhu Forging Ltd. CENVAT credit refund treated as capital receipt not includible in book profit u/s 115JB. Export incentives and other income allowed as part of eligible profits for 80IB deduction. Case-Laws Income Tax Thu, 25 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448788