“Section 36(1)(viii)”

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD., KASTURBA NAGAR

report dated 07.03.2023\n(PB Pg. 802 to 807)\n2.3.3 To support our contention, we have reproduced herein below the\nrelevant extract of Section 36(1)(viii) for your easy reference:-\n\"In respect of any special reserve created and maintained by a\nspecified entity, an amount not exceeding twenty ... nbusiness. Therefore, all these categories of incomes which the\nassessee is receiving as a direct nexus with the long term finance and\ntherefore Section 36(1)(viii) of the Act is attracted. Therefore, we do\nnot see any merit in these appeals. Accordingly, the first substantial\nquestion

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

report dated 07.03.2023\n(PB Pg. 802 to 807)\n2.3.3 To support our contention, we have reproduced herein below the\nrelevant extract of Section 36(1)(viii) for your easy reference:-\n12\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA Nos.609& 579/Del/2025\n\"In respect of any special reserve created ... nbusiness. Therefore, all these categories of incomes which the\nassessee is receiving as a direct nexus with the long term finance and\ntherefore Section 36(1)(viii) of the Act is attracted. Therefore, we do\nnot see any merit in these appeals. Accordingly, the first substantial\nquestion

JCIT(OSD), RANGE-10, NEW DELHI , CR BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

report dated 07.03.2023\n(PB Pg. 802 to 807)\n2.3.3 To support our contention, we have reproduced herein below the\nrelevant extract of Section 36(1)(viii) for your easy reference:-\n\"In respect of any special reserve created and maintained by a\nspecified entity, an amount not exceeding twenty ... nbusiness. Therefore, all these categories of incomes which the\nassessee is receiving as a direct nexus with the long term finance and\ntherefore Section 36(1)(viii) of the Act is attracted. Therefore, we do\nnot see any merit in these appeals. Accordingly, the first substantial\nquestion

JCIT(OSD), RANGE-10, NEW DELHI , ITO C.R. BUILDING vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

report dated 07.03.2023\n(PB Pg. 802 to 807)\n2.3.3 To support our contention, we have reproduced herein below the\nrelevant extract of Section 36(1)(viii) for your easy reference:-\n12\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA Nos.609& 579/Del/2025\n\"In respect of any special reserve created ... nbusiness. Therefore, all these categories of incomes which the\nassessee is receiving as a direct nexus with the long term finance and\ntherefore Section 36(1)(viii) of the Act is attracted. Therefore, we do\nnot see any merit in these appeals. Accordingly, the first substantial\nquestion

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

report dated 07.03.2023\n(PB Pg. 802 to 807)\n2.3.3 To support our contention, we have reproduced herein below the\nrelevant extract of Section 36(1)(viii) for your easy reference:-\n12\n\"In respect of any special reserve created and maintained by a\nspecified entity, an amount not exceeding ... nbusiness. Therefore, all these categories of incomes which the\nassessee is receiving as a direct nexus with the long term finance and\ntherefore Section 36(1)(viii) of the Act is attracted. Therefore, we do\nnot see any merit in these appeals. Accordingly, the first substantial\nquestion

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

report dated 07.03.2023\n(PB Pg. 802 to 807)\n2.3.3 To support our contention, we have reproduced herein below the\nrelevant extract of Section 36(1)(viii) for your easy reference:-\n12\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA Nos.609& 579/Del/2025\n\"In respect of any special reserve created ... nbusiness. Therefore, all these categories of incomes which the\nassessee is receiving as a direct nexus with the long term finance and\ntherefore Section 36(1)(viii) of the Act is attracted. Therefore, we do\nnot see any merit in these appeals. Accordingly, the first substantial\nquestion

INDIA INFRASTRUCTURE FINANCE COMPANY LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, I.P. ESTATE, NEW DELHI

provision of section 26(1)(viii) of the Act.\nPage | 10\nITA No.4170/Del/2025 & 5552/Del/2024\n29. Ld.AR further submits that in terms of section 36(1)(viii) of the\nAct, any amount transferred to special reserve, 20% of the amount of\nprofits is allowed as the deduction with a rider that ... amount over and above, the actual amount\ncharged to Profit & Loss Account as transferred to special reserve.\nThe limits provided in section 36(1)(viii) of the Act with respect to\nmaximum amount allowable as deduction for the amount transferred\nto the special reserve by the special entities as provided

JCIT(OSD), CIRCLE -10(1), DELHI vs. M/S INDIAN INFRASTRUCTURE FINANCE COMPANY LIMITED, DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘E’ BENCH, NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER, AND SHRI

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 10(1), DELHI, DELHI

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 10(1), DELHI, DELHI

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 10(1), DELHI, DELHI

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed

INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 10(1), DELHI, DELHI

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

declaring total income of Rs.129,63,24,480/-. In the return of income, the assessee claimed deduction of Rs.29,53,53,159/- under section 36(1)(viii) of the Act, being 20% of the profits from long-term financing business. Ld. Counsel explained the said deduction was computed as under ... same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible for deduction under section 36(1)(viii) of the Act and consequently, denied the entire claim of deduction under that section. 6. On further appeal, the CIT(A) partly allowed