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    <title>2025 (6) TMI 1295 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=773182</link>
    <description>The note discusses multiple ITAT issues on deduction and income classification under the Income-tax Act, including leave encashment, productivity-linked incentives, prior period expenses, post-amalgamation pre-operative expenses, provident fund timing, section 80HHC computation, section 14A disallowance, and foreign tax credit. It records that leave encashment and productivity-linked incentive provisions were treated as deductible business expenses, pre-operative expenses of the amalgamated company were held outside the BIFR/section 72A cap, and net interest was relevant for section 80HHC. It also notes that prior period expenses were included in indirect cost, provident fund paid after the due date was disallowed, dividend income remained outside business income, section 14A applied on a reasonable estimate basis, and foreign tax credit was remanded for consideration.</description>
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    <pubDate>Wed, 23 Apr 2025 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 1295 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=773182</link>
      <description>The note discusses multiple ITAT issues on deduction and income classification under the Income-tax Act, including leave encashment, productivity-linked incentives, prior period expenses, post-amalgamation pre-operative expenses, provident fund timing, section 80HHC computation, section 14A disallowance, and foreign tax credit. It records that leave encashment and productivity-linked incentive provisions were treated as deductible business expenses, pre-operative expenses of the amalgamated company were held outside the BIFR/section 72A cap, and net interest was relevant for section 80HHC. It also notes that prior period expenses were included in indirect cost, provident fund paid after the due date was disallowed, dividend income remained outside business income, section 14A applied on a reasonable estimate basis, and foreign tax credit was remanded for consideration.</description>
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      <pubDate>Wed, 23 Apr 2025 00:00:00 +0530</pubDate>
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