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2018 (3) TMI 468 - AT - Income TaxDeduction U/S 80-IB - scope of term 'manufacture' occurring in the context of section 80-IB - profits derived by the Assessee from manufacture and sale of poultry feed - Held that:- As decided in assessee's own case [2017 (4) TMI 1316 - ITAT KOLKATA] in the light of the admitted factual position that the income in question had direct nexus with the business of the assessee, the same was rightly held by CIT(A) to be eligible for the purpose of claiming deduction u/s 80IB(5). We do not find any ground to interfere with the order of CIT(A). Disallowance of expenses u/s.14A r.w.r. 8D(2)(ii) & (iii) - Held that:- As far as disallowance under Rule 8D(2)(iii) is concerned, we are of the view that it is only the investment which yield dividend income that should be considered for the purpose of applying the formula as confirmed in in the case of REI Agro Ltd. [2014 (4) TMI 713 - CALCUTTA HIGH COURT]. As far as investments made in subsidiaries is concerned, such investments made in subsidiaries would fall under the category of strategic investments as they are admittedly made only for the purpose of obtaining controlling interest in the said companies and not for the purpose of earning dividend income which is exempt. Hence they would stand differently from other regular investments. - Decided against revenue
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