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2020 (3) TMI 51 - PUNJAB & HARYANA HIGH COURTDeduction of lease income and interest income under Section 80HHC - Whether lease income and interest income from loans and advances to the sister concerns will come in the domain of 'income from other sources'? - HELD THAT:- Once it is accepted that the income from lease and interest income is income from other sources, there is no question of it being eligible under Section 80HHC of the Act. The provision deals with deductions in respect of profits retained for export business. The income earned from interest and lease money is not income under the head 'profits and gains of business or profession'. In the facts of the present case, there is no question of setting off/adjusting the interest on debit side and on the credit side of the profit and loss account. The interest paid by the assessee is directly linked with the business and would be dealt with while calculating the income from business or profession. The lease money and interest income is not income from the business, rather it is income from application of money which might have been earned from business or profession. In such circumstances, there would be no question of netting/setting off the interest paid vis-a-vis the interest received. The Tribunal rightly rejected the contention of the assessee. In the present case, the interest received and the lease money is not even includable in the profits and gains determined under the head “profits and gains of business or profession”. Appeal dismissed.
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