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2013 (11) TMI 138 - ITAT MUMBAIProfits u/s section 80HHC – Held that:- Following case of Pfizer Ltd. [2010 (6) TMI 433 - Bombay High Court] - The claim on account of insurance for the stock-in-trade did not constitute a receipt of a similar nature within the meaning of Explanation (baa) - Insurance receipts are intimately connected to the business activities of the assessee thus constitutes operational income - No need for reducing 90 per cent of the insurance claim while computing the eligible profits under section 80HHC. Sale of scrap and miscellaneous receipts – Held that:- Following Dresser Rand India P. Ltd [2010 (4) TMI 664 - Bombay High Court] – The scrap was the combination of both scrap generated as a part of the manufacturing activities as well as scrap of the packing material attached to the imported consignments The issue go to the files of the Commissioner of Income-tax (Appeals) for redeciding the issue afresh. Technology transfer Receipts – Held that:- Following case of Motor Industries Co. Ltd [2010 (8) TMI 333 - Karnataka High Court] - The developmental work is intimately connected with the business of manufacture and sale of goods by the assessee. There is immediate nexus between the activity of export and the developmental work. Admittedly, for the services rendered by way of these developmental work, the assessee has been given the benefit of deductions under section 80-O – Decided in favour of assessee.
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