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    <title>2025 (5) TMI 108 - ITAT LUCKNOW</title>
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    <description>Commission received by Cane Development Councils and Cooperative Cane Development Unions from sugar mills for cane supply and related statutory activities was treated as business income attributable to their cane-related functions, not income from other sources. Because those functions were integrally connected with the statutory framework governing sugarcane production, supply and marketing under the U.P. Sugarcane (Regulation of Supply &amp; Purchases) Act, 1953 and the Rules, 1954, the receipts qualified for deduction under section 80P of the Income-tax Act, 1961. The Revenue&#039;s objection that no factual finding existed on the nature of the commission was rejected, as the appellate finding was based on the statutory duties and the manner in which the commission arose.</description>
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      <link>https://www.taxtmi.com/caselaws?id=769836</link>
      <description>Commission received by Cane Development Councils and Cooperative Cane Development Unions from sugar mills for cane supply and related statutory activities was treated as business income attributable to their cane-related functions, not income from other sources. Because those functions were integrally connected with the statutory framework governing sugarcane production, supply and marketing under the U.P. Sugarcane (Regulation of Supply &amp; Purchases) Act, 1953 and the Rules, 1954, the receipts qualified for deduction under section 80P of the Income-tax Act, 1961. The Revenue&#039;s objection that no factual finding existed on the nature of the commission was rejected, as the appellate finding was based on the statutory duties and the manner in which the commission arose.</description>
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