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2011 (12) TMI 350 - AT - Income TaxDeduction u/s 80HHC - assessee has entered into an agreement with the Yanbu Cement Company Ltd to offer technical knowhow for the operation, maintenance and efficient working of their cement plants - It is the claim of the assessee that the receipt is nothing but income arising in the course of main business, hence to be considered as 'profits of the business' for the purpose of deduction under section 80HHC - Even though the assessee claims that it is operational income to be considered as 'profits of business', these receipts have no direct relationship with the assessee's claim under section 80HHC on export of goods - Considering that assessee originally excluded the same and only contested before the ITAT as additional ground - Decided against the assessee Regarding deduction u/s 80I - assessee included miscellaneous receipts as profit and gains of business while computing deduction under section 80I in respect of Madukarai Unit - learned counsel fairly submitted that the assessee was not in a position to correlate the amounts received as rent from outside parties as recovery of the amounts paid and other receipts, details of which are not available at present - Assessee could not relate the receipt of the above income to the industrial unit for claim of deduction under section 80I - Decided against the assessee
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