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    <title>2023 (5) TMI 1507 - ITAT MUMBAI</title>
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    <description>Section 80-IA deduction attaches to eligible rail and power undertakings and remains available after amalgamation; captive use does not bar eligible-profit computation. Investment allowance was available for capital work-in-progress components installed and commissioned as part of an integrated plant, while balance additional depreciation could be claimed in the succeeding year. Sales-tax incentives linked to establishing units in backward areas were capital receipts, and further section 14A disallowance required recorded dissatisfaction with the taxpayer&#039;s accounts. Valid TDS/TCS certificates supported credit subject to verification. Research deduction could not be limited to Form 3CL quantification for the relevant period, and uncredited refund interest could not increase book profit. CSR assets did not qualify for depreciation; corporate guarantee pricing was 0.5%.</description>
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      <description>Section 80-IA deduction attaches to eligible rail and power undertakings and remains available after amalgamation; captive use does not bar eligible-profit computation. Investment allowance was available for capital work-in-progress components installed and commissioned as part of an integrated plant, while balance additional depreciation could be claimed in the succeeding year. Sales-tax incentives linked to establishing units in backward areas were capital receipts, and further section 14A disallowance required recorded dissatisfaction with the taxpayer&#039;s accounts. Valid TDS/TCS certificates supported credit subject to verification. Research deduction could not be limited to Form 3CL quantification for the relevant period, and uncredited refund interest could not increase book profit. CSR assets did not qualify for depreciation; corporate guarantee pricing was 0.5%.</description>
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