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2022 (3) TMI 716 - AT - Income TaxEligible income for the purpose of deduction u/s 80IE - Exclusion of miscellaneous income being recovery of excess cost charged by suppliers of goods from the profits eligible for deduction under Section 80IE - HELD THAT:- Upon considering the entire facts we find that the recovery of excess cost charged by the supplier is extricably connected with income of the industrial undertaking as of the undertaking of the appellant company and therefore, is entitled to deduction under Section 80IE of the Act. We, thus, allow the said deduction in respect of the appellant company under Section 80IE of the Act. The AO is directed to grant relief to the appellant accordingly. This ground of appeal preferred by the assessee is, therefore, allowed. Exclusion of income earned in the nature of cash discount from the profits eligible for deduction under Section 80IE - HELD THAT:- As relyig on the case of Nirma Ltd. [2014 (12) TMI 171 - GUJARAT HIGH COURT] the cash discount received as above is eligible for deduction under Section 80IE of the Act and we, therefore, allow this ground of appeal in favour of the assessee. Exclusion of interest income earned by the appellant from the profit eligible for deduction under Section 80IE - HELD THAT:- On the aspect of netting off of interest income we have considered the judgment passed by the Jurisdictional High Court in the case of Nirmal Ltd. [2014 (12) TMI 171 - GUJARAT HIGH COURT] we find it fit and proper to allow this ground of appeal filed by the assessee by directing the AO to re-compute the addition upon netting off of interest income by excluding the same from profits eligible for deduction under Section 80IE of the Act of the appellant undertaking, in the light of the above observation made.
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