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2022 (6) TMI 1025 - HC - Income TaxDeduction u/s 80HHC - Income from storage and handling and other receipts was to form part of total turnover or not? - HELD THAT:- As from the reading of the orders of the Assessing Officer, Commissioner of Income Tax (Appeals) and the Tribunal, what emerges is that the income from storage and handling which form major component was independent of the export of leather and molasses which the Appellant undertook as an export business. Further, in the appeal the Appellant has made a statement on oath, which is not controverted that it is engaged in the business of export of leather and molasses and storage and handling of liquid cargo at major ports. Not only that nothing contrary as regard this assertion is shown, in fact, the authorities have proceeded on the basis that the storage and handling of liquid cargo at major ports was a different business of leather and molasses. That being the position, in the light of law laid down in the case of Punjab Stainless Steel [2014 (5) TMI 238 - SUPREME COURT], the Appellant is entitled to succeed on second component and accordingly, the question of law framed will have to be answered in favour of the Appellant.
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