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2011 (3) TMI 819 - HIMACHAL PRADESH HIGH COURTDeduction u/s 80IA - Transport subsidy - In the case of CIT v. Sterling Foods (1999 -TMI - 5740 - SUPREME Court), had made a distinction between the words “derived from” and “attributable to - Any incidental income or profit to the business of the assessee or to the income of the industrial undertaking is not entitled or eligible for the benefit of section 80HH - Subsidy or transport subsidy is not the immediate source or have direct nexus with the activity of the industrial undertaking. It is an aid by the Government under the Scheme - Held that: the source of income transport subsidy is not the business of the assessee but the scheme framed by the Central Government - Decided against the assessee
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