9911796707
TMI Blog2002 (9) TMI 75X X X X Extracts X X X X X X X X Extracts X X X X ..... ther, on the facts and in the circumstances of the case, the Appellate Tribunal is right in law in holding that the interest income derived by the assessee from funds in connection with letter of credit is income derived from the profits of the business of the industrial undertaking so as to be entitled to get the benefit of section 10A of the Income-tax Act, 1961?". The assessee had set up a new ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ains derived by an assessee from an industrial undertaking to which that section applies shall not be included in the total income of the assessee. The Supreme Court in the case of Cambay Electric Supply Industrial Co. Ltd. v. CIT [1978] 113 ITR 84 has held that the words "derived from" are narrower in scope than the words "attributable to". In the case of CIT v. Sterling Foods [1999] 237 ITR 579 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee was on deposits made by it in the banks. It is that deposit which is the source of income. The mere fact that the deposit made was for the purpose of obtaining letters of credit which letters of credit were in turn used for the purpose of the business of the industrial undertaking does not establish a direct nexus between the interest and the industrial undertaking. The Tribunal, therefore, ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
