TMI Blog2002 (9) TMI 75X X X X Extracts X X X X X X X X Extracts X X X X ..... ss of the industrial undertaking so as to be entitled to get the benefit of section 10A of the Income-tax Act, 1961?". - In this case the interest received by the assessee 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 industrial undertaking in Kandla Free Trade zone for the manufacture of light engineering goods. The goods therein were exported during the assessment year 1985-86. In the course of the business of that industrial undertaking, the assessee was required to open letters o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rds "derived from" are narrower in scope than the words "attributable to". In the case of CIT v. Sterling Foods [1999] 237 ITR 579, the Supreme Court observed that: "the word 'derive' is usually followed by the word 'from' and it means: 'get, to trace from a source; arise from, originate in, show the origin or formation of'". It was pointed out that unless the source of the income is from an ind ..... X X X X Extracts X X X X X X X X Extracts X X X X
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