https://www.taxtmi.com/caselaws?id=773350 ITAT Rajkot allowed the assessee's appeal on three grounds. First, write-off amounts due to court-approved capital reduction constituted transfer under section 2(47) and were not includible in book profit computation under section 115JB. Second, CIT(A) erred by directing deemed dividend assessment under sections 2(22)(d) and 115QA without issuing mandatory show-cause notice for enhancement, violating section 251(2). Third, rental income from Container Freight Station operations qualified for section 80IA deduction as it formed part of eligible industrial undertaking income, consistent with previous years' decisions and CBDT circular. en-us Fri, 30 May 2025 00:00:00 +0530 Sat, 21 Jun 2025 08:28:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773350 ITAT Rajkot allowed the assessee's appeal on three grounds. First, write-off amounts due to court-approved capital reduction constituted transfer under section 2(47) and were not includible in book profit computation under section 115JB. Second, CIT(A) erred by directing deemed dividend assessment under sections 2(22)(d) and 115QA without issuing mandatory show-cause notice for enhancement, violating section 251(2). Third, rental income from Container Freight Station operations qualified for section 80IA deduction as it formed part of eligible industrial undertaking income, consistent with previous years' decisions and CBDT circular. Case-Laws Income Tax Fri, 30 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773350