https://www.taxtmi.com/caselaws?id=782528 ITAT Ahmedabad partly allowed the assessee's appeal against a revision order u/s 263. It held that deduction u/s 36(1)(viia) must be computed with reference to "total income" (including capital gains) before deductions under that clause and Chapter VI-A, as expressly provided by the statute. The AO's computation on total income, including capital gains, was a plausible, legally sustainable view reached after due enquiry, and thus the assessment was neither erroneous nor prejudicial to the interests of Revenue on this issue. Consequently, the Principal CIT's direction to restrict the deduction to business income was set aside. However, revision regarding disallowance u/s 14A was upheld. en-us Thu, 27 Nov 2025 00:00:00 +0530 Wed, 03 Dec 2025 15:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782528 ITAT Ahmedabad partly allowed the assessee's appeal against a revision order u/s 263. It held that deduction u/s 36(1)(viia) must be computed with reference to "total income" (including capital gains) before deductions under that clause and Chapter VI-A, as expressly provided by the statute. The AO's computation on total income, including capital gains, was a plausible, legally sustainable view reached after due enquiry, and thus the assessment was neither erroneous nor prejudicial to the interests of Revenue on this issue. Consequently, the Principal CIT's direction to restrict the deduction to business income was set aside. However, revision regarding disallowance u/s 14A was upheld. Case-Laws Income Tax Thu, 27 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782528