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2014 (5) TMI 1100 - AT - Income TaxEligibility for deduction u/s.80P(2)(a)(i) - to whether the addition if any sustained u/s. 40(a)(ia) is eligible for deduction u/s.80P(2)(a)(i)? - Held that:- Addition made u/s.40(a)(ia) has to be allowed as deduction u/s.80P(2)(a)(i) of the I.T. Act. See Pharande Developers Versus ITO [2013 (6) TMI 690 - ITAT PUNE ]. In this view of the matter, the ground raised by the Revenue is accordingly dismissed.- Decided in favour of assessee Addition on gross amount of MSEB commission - Held that:- We find merit in the submission of the Ld. Counsel for the assessee that pro-rata expenditure should be allowed to the assessee for earning the commission since the assessee has to incur various expenditure and such pro-rate expenditure comes to 91.40%. If the said rate is applied then the net income from MSEB commission after considering the expenditure works out to ₹ 19,531/- which is below ₹ 50,000/- and is eligible for deduction u/s.80P(2)(c). - Decided in favour of assessee
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