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2011 (12) TMI 524 - AT - Income TaxClaim for deduction u/s 80IA in respect of sales-tax benefit - connotation of the words “derived from” and “attributable to” - Held that:- We uphold the impugned order of the learned CIT(Appeals) confirming the action of the AO in disallowing the assessee’s claim for deduction u/s 80IA(4) in respect of sales-tax benefit, the immediate source of which is the relevant scheme of State Govt. and not the eligible business of the industrial undertaking of the assessee CIT(Appeals) has already allowed deduction on account of office and administrative expenses on pro-rata basis from the amount of sales-tax benefit received by the assessee which is liable to be excluded from the profits eligible for deduction u/s 80IA(4). As regards the interest and other expenses, the learned counsel for the assessee has not been able to raise any arguments to convince us that the said expenditure was directly or indirectly attributable to the earning of sales-tax benefit. He has not been able to explain as to what could be the expenditure involved under the said heads which can be said to have been incurred for the purpose of earning sales-tax benefit which has been received by the assessee under the scheme of the State Govt. We, therefore, find no merit in ground No.2 raised by the assessee and dismiss the same.
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