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“eligible business”

DeductionsSection 80IASection 80IA975 judgments

The decision most relied on for eligible business is Totgars Co-operative Sale Society Ltd. v. ITO (322 ITR 283), cited in 1,283 judgments on BharatTax.

Leading authorities on eligible business

Totgars Co-operative Sale Society Ltd. v. ITO
322 ITR 283 · 2010 · Supreme Court
1,283
citing judgments

The interest income earned by a cooperative society from investing its surplus funds in fixed deposits with banks is not "derived from" its eligible business activities and is taxable as "income from other sources" under Section 56, thus not qualifying for deduction under Section 80P.

State Bank Of India v. CIT
389 ITR 578 · 2016 · High Court
817
citing judgments

Income arising from a cooperative society's surplus funds invested in short-term deposits and securities is not attributable to the society's core activities and, therefore, is not eligible for exemption under Section 80P(2)(a)(i) of the Income-tax Act.

Liberty India v. CIT
317 ITR 218 · 2009 · Supreme Court
571
citing judgments

The Supreme Court clarified that for profits and gains to be eligible for deductions under sections like 10B, 80IA, or 80IB, the income must be "derived from" or have a direct nexus to the eligible business activity. Income from incidental sources like the sale of scrips/licenses or interest on employee loans is generally not considered as derived from the eligible business for such deductions.

CIT v. Smifs Securities Ltd.
348 ITR 302 · 2012 · Supreme Court
540
citing judgments

Goodwill, whether arising from an amalgamation or a slump sale, is an intangible asset eligible for depreciation under Section 32(1) of the Income-tax Act. While the assessee must prove the existence and valuation of such goodwill, it is recognized as a depreciable asset.

Citizen Co-operative Society Ltd. v. ACIT
397 ITR 1 · 2017 · Supreme Court
499
citing judgments

A co-operative credit society engaged in banking business with the general public, accepting deposits from non-members and advancing loans to non-members, is treated as a co-operative bank. Such a society falls under the exclusionary clause of Section 80P(4) and is not eligible for deduction under Section 80P(2)(a)(i).

Totgar's Co-operative Sale Society Ltd. v. ITO
188 Taxmann 282 · 2010 · Supreme Court
486
citing judgments

Interest income earned by a co-operative society from investments, particularly with co-operative banks, is not eligible for deduction under Section 80P as it is not attributable to the core business activities of the society and constitutes "other income", not "profits and gains of business".

Pandian Chemicals Ltd. v. CIT
262 ITR 278 · 2003 · Supreme Court
353
citing judgments

Income eligible for deduction under Section 80IA or 80IC must have a direct nexus with the eligible business activity of the industrial undertaking. Income merely incidental to the business, even if part of the assessee's overall business, is not considered "derived from" the eligible undertaking.

CIT v. Sterling Foods
237 ITR 579 · 1999 · Supreme Court
311
citing judgments

Income eligible for profit-linked deductions under sections like 80-IC or 10B must have a direct nexus to the eligible business activity or be derived from the industrial undertaking itself, and not merely attributable to it or arising from a post-manufacturing event.

Judgments citing eligible business

The Karnataka State Cooperative Agriculture and Development Bank Limited, Banglaore vs. Income Tax Officer, Ward-5(2)(1), Bengaluru

In the result the appeal of the assessee is partly allowed for statistical purposes

ITA 1821/BANG/2025[2022-23]Status: DisposedITAT Bangalore09 Apr 2026AY 2022-23

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2022-23

For Appellant: Shri Bhardwaj Sheshadri, Advocate &For Respondent: Shri Subramanian, JCIT (DR)
Section 250Section 56Section 80PSection 80P(2)(a)

further submitted that there is no separate computation of income from other sources in the assessment order and the AO has wrongly subjected eligible business income to tax by reducing the deduction under Chapter VI-A of the Act. The assessee placed reliance on the decision of the ITAT, Bangalore ... deduction under section 80P(2)(a)(i) on income enhanced due to such disallowances, as the deduction is allowable only on income attributable to eligible business activity and not on income resulting from tax adjustments. Accordingly, the grounds raised by the assessee were dismissed. 25. Being aggrieved by the order

Manoj Rajaram Sharma, Thane vs. Commissioner of Income-Tax, Mumbai

In the result, the appeal of the assessee is allowed

ITA 8313/MUM/2025[2020-2021]Status: DisposedITAT Mumbai20 Mar 2026AY 2020-2021

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokarmanoj Rajaram Ito - 42(3)(4), Sharma, Mumbai Office No. 615, 6Th Vs. Kautilya Bhawan, C- Floor, Centura Square 41-43, Avenue 3, Near It Park, Sg Barve Videsh Bhavan, G Road, Thane, Block, Bkc, Mumbai Maharashtra-400 604. – 400 051. Pan/Gir No. Bytps1944K (Applicant) (Respondent) Assessee By Shri Suryadev Yadav, Shri Karan Hariya & Shri Prashant Gupta, Ld. Ars Revenue By Shri Bhagirath Ramawat, Ld. Dr Date Of Hearing 17.03.2026 Date Of Pronouncement 20.03.2026

Section 133(6)Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 272A(1)(d)Section 4Section 44A

itself misplaced. 16. It is apposite to examine the statutory scheme of presumptive taxation. Section 44AD applies to eligible assessees engaged in eligible business, and provides for taxation of income at 8% (or 6% in specified cases) of the total turnover or gross receipts. Section 44ADA, on the other hand

Deoband Cooperative Cane Development Union Ltd, Deopand Saharanpur vs. Assessing Officer, NFAC Delhi (Assessment Unit)

Appeal is allowed in above terms

ITA 6638/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumara.Yr. : 2022-23 Deoband Cooperative Vs. Ao, Nfac, Delhi Cane Development Union (Assessment Unit) Ltd., Office Of Cooperative Cane Development Deoband, Uttar Pradesh-247554 (Pan: Aaaad0519J)

For Appellant: Sh. J.N. Shukla, AdvFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR
Section 80Section 80PSection 80P(2)Section 80P(2)(a)

Sale Society Ltd. Vs. ITO 322 ITR 283 (SC) that such an interest income could not be held to have been derived from the eligible business u/s 80P(2) of the Act. 5. We find no merit in the Revenue’s instant vehement arguments in light of (2024) 164 taxmann.com

Granules India Limited, Hyderabad vs. DCIT, Circle-2(1), Hyderabad

In the result, appeal filed by the assessee is dismissed

ITA 1289/HYD/2025[2010-11]Status: DisposedITAT Hyderabad13 Mar 2026AY 2010-11

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआयकर अपील सं / Ita No.1289/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2010-11) Granules India Limited Vs. Dcit- Circle -2(1) 15Th Floor, Granules Tower Signature Tower, Botanical Garden Road Sy. No. 6(P) Of Kondaput Kondapur, Hyderabad – 500084 Sy. No. 37 Of Kothaguda Telangana Opp. Botanical Gardens Serilingampalluy, R.R. District Pan: Aaacg7369K Hyderabad-500084, Telangana (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent)

Section 10BSection 143(3)Section 148Section 154Section 271(1)(c)

taking note of the relevant submissions of the assessee and also the deduction claimed under section 10B of the Act towards profit from the eligible business which includes the gain received on foreign exchange fluctuations on account of External Commercial Borrowing (in short “ECB”) and sale of scrap and insurance

Shri Ghulam Nabi Lone, Anantnag vs. Income Tax Officer Ward, Anantnag

In the result, the appeal of the assessee is partly allowed

ITA 624/ASR/2024[2017-18]Status: DisposedITAT Amritsar12 Mar 2026AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 624/Asr/2024 Assessment Year: 2017-18 Sh. Ghulam Nabi Lone, Vs. Ito, Ward, Dangarpora, Siligam, Pahalgam, Anantnag. Ananthnag, Jammu & Kashmir. [Pan:-Ahypl1427H] (Appellant) (Respondent) Appellant By None (Written Submission) Respondent By Sh. Charan Dass, Sr. Dr

Section 142(1)Section 144Section 250Section 69A

admitted by the assessee, no books of accounts are existing. 10. The business of trading in shawl and handicrafts, falls under the category of “eligible business”, and is covered by the presumptive section of 44AD of the Act 61. 10.1 As such instead of remanding the matter back

Sharayu Synthetics Processors, Bhiwandi vs. DCIT Appeal, Kalyan

In the result, the appeal of the assessee is partly allowed

ITA 7172/MUM/2025[2018-2019]Status: DisposedITAT Mumbai10 Mar 2026AY 2018-2019

Bench: Shri Saktijit Dey & Shri Jagadishassessment Year: 2018-19 Sharayu Synthetics Vs. Dcit Appeal Processors Mohan Plaza Khadakpada Kalyan, Kalyan-Dombivali, H No 1662 Saraswati Maharashtra-421301 Compound, Near Ganesh Society, Bhiwandi, Maharashtra- 421302

Section 143(3)Section 145(3)Section 250Section 44A

income at the rate of 8% by drawing analogy from section 44AD is also not justified as the said provision applies only to eligible businesses within the prescribed turnover limit whereas the turnover of the assessee in the present case exceeds Rs.28 crore. 8. At the same time

Easwaramurthy Prakash, Coimbatore vs. ITO, Ward-1(2), Tirupur

In the result, the appeal of the assessee is partly allowed

ITA 2247/CHNY/2025[2016-17]Status: DisposedITAT Chennai09 Mar 2026AY 2016-17

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. Suraj Nahar, CAFor Respondent: Shri. N. Rajakumar, Addl.CIT
Section 144Section 147Section 148Section 44A

presumptive provisions of section 44AD of the Act. While section 44AD of the Act provides for a presumptive rate of 8% in respect of eligible businesses, we are of the considered view that the said provision cannot be applied mechanically for the purpose of estimating income in every case, particularly

Valuelabs LLP, Hyderabad vs. DCIT., Central Circle 8(1), Hyderabad

ITA 1609/HYD/2025[2020-21]Status: DisposedITAT Hyderabad06 Mar 2026AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी. सं/Ita No.1609/Hyd/2025 (निर्धारण वर्ष/Assessment Year:2020-21) Valuelabs Llp, Hyderabad. Vs. Dcit, Pan: Aakfv2276K Central Circle-8(1), Hyderabad. (Appellant) (Respondent) निर्धारिती द्वारा/Assessee By: Shri P. Murali Mohan, Ca राजस्व द्वारा / Revenue By: Ms. U. Mini Chandran, Cit-Dr सुनवाई की तारीख / Date Of Hearing: 29/01/2026 घोषणा की तारीख / Date Of 06/03/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 13/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) R.W.S 144B Of The Income Tax Act, 1961 (For Short, "The Act"), Dated 27/09/2022 For The Assessment Year (Ay) 23/11/2021. The Assessee Firm Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri P. Murali Mohan, CAFor Respondent: Ms. U. Mini Chandran
Section 115BSection 143(3)Section 2(24)(xviii)Section 250Section 80

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad Before Shri Manjunatha G., Accountant

Navakarnataka Pss Limited, Hospet vs. Income Tax Officer, Ward-1 & Tps, Hospet

In the result, the appeal filed by the assessee is allowed

ITA 2167/BANG/2025[2016-17]Status: DisposedITAT Bangalore05 Mar 2026AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Smt. Harsha, CAFor Respondent: Shri Subramanian .S, JCIT-DR
Section 142(1)Section 143(2)Section 194ASection 194A(3)(v)Section 2(19)Section 234ASection 250Section 40Section 40aSection 80P

relied on the Circular No. 37/2016 dated 02/11/2016 in which it was clarified that the disallowances result in enhancement of the profits of the eligible business and therefore deduction under Chapter VIA is admissible on the profits so enhanced by the disallowance. We have already decided that the assessee

DCIT-13(1)(1), Mumbai vs. M/S Oracle Financial Services Software Ltd., Mumbai

ITA 3995/MUM/2019[2008-09]Status: DisposedITAT Mumbai19 Feb 2026AY 2008-09

Bench: Smt. Beena Pillai () & Shri Girish Agrawal, () Ι.Τ.Α. No. 3432/Mum/2019

Section 14A

IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) & SHRI GIRISH AGRAWAL, (ACCOUNTANT MEMBER

Oracle Financial Services Software Limited, Mumbai vs. ACIT-13(1)(1), Mumbai

ITA 3432/MUM/2019[2008-09]Status: DisposedITAT Mumbai19 Feb 2026AY 2008-09

Bench: Smt. Beena Pillai () & Shri Girish Agrawal, () Ι.Τ.Α. No. 3432/Mum/2019

Section 14A

IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) & SHRI GIRISH AGRAWAL, (ACCOUNTANT MEMBER

Clover Developers Pvt Ltd, Mumbai vs. Dy CIT 6(1)(1), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 7922/MUM/2025[2012-13]Status: DisposedITAT Mumbai16 Feb 2026AY 2012-13

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2012-13 Clover Developers Pvt. Ltd., Dcit-6(1)(1), Flat No. 12, Mumbai. 1St Floor, Plot No. 541/C, Vs. Ashok Building, Edenwalla Road, Matunga, Mumbai-400019. Pan : Aaacg1925B (Appellant) (Respondent) For Assessee : Shri K. Gopal A/W. Shri Akhilesh Deshmukh For Revenue : Shri Virabhadra Mahajan, Sr.Dr Date Of Hearing : 11-02-2026 Date Of Pronouncement : 16-02-2026 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Shri K. Gopal a/wFor Respondent: Shri Virabhadra Mahajan, Sr.DR
Section 143(3)Section 271(1)(c)Section 80Section 801ASection 80I

According to the AO, the actual depreciation of the earlier years in respect of wind mill is not to be allowed against the non-eligible business of the assessee whereas the contention of the assessee is that unabsorbed brought forward depreciation can not be set off against the initial year

Chawla Auto Corporation, Rudrapur vs. A C I T Circle-2(1)(1), Haldwani

In the result, appeal of the assessee is partly allowed

ITA 140/DDN/2025[2017-18]Status: DisposedITAT Dehradun13 Feb 2026AY 2017-18

Bench: SHRI YOGESH KUMAR U.S (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 250Section 80Section 80I

profits of Unit-1. Ld. AR further submits that assessee has claimed deduction u/s 80-IC @ 25% of the profits of eligible business and therefore, there would not be much difference between the taxes paid on the profits of Unit-1 and Unit-2. It is thus prayed that

M/S Shivansh Infraestate Pvt.Ltd., Lucknow vs. Dy. CIT Range-6, Lucknow

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 106/LKW/2024[2015-16]Status: DisposedITAT Lucknow13 Feb 2026AY 2015-16

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2015-16 M/S Shivansh Infraestate Pvt. Ltd., Vs. The Deputy Commissioner Of 3Rd Floor, Block-A, Surajdeep Income Tax, Range-6, 3Rd Floor, Complex, 1-Jopling Road, 27/2, Raja Ram Mohan Rai Marg, Lucknow-226001 P.K. Complex, Lucknow Pan: Aaqcs5896P (Appellant) (Respondent) Assessee By: Sh. Shubham Rastogi, C.A. Revenue By: Sh. Neeraj Kumar, Cit Dr Date Of Hearing: 20.11.2025 Date Of Pronouncement: 13.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Passed Under Section 250 Of The Income Tax Act, 1961 On 18.01.2024 Wherein The Ld. Cit(A) Has Partly Allowed The Appeals Of The Assessee Against The Orders Of The Ld. Assessing Officer Dated 30.12.2017. The Grounds Of Appeal Are As Under:- “1- The Ld. Cit (A) Nfac Erred On Facts & In Law In Dismissing The Ground That Notice U/S 143(2) Was Issued By Ito-6(1) Lucknow On 01.04.2016 Without Appreciating That Jurisdiction Of Case Lies With Dcit, Range-6, Lucknow, Hence The Notice Issued By Ito-6(1) Is Without Jurisdiction & Invalid. Further, No Notice U/S 143(2) Has Been Issued By Jurisdictional Dcit, Range-Vi, Lucknow Within The Period As Per Section 143(2) Of L. T. Act. Hence The Present Assessment Is Invalid, Bad In Law & Liable To Be Quashed. 2- The Ld. C.I.T. (A) Upheld The Addition Without Appreciating That Ld. A. O. Rejected The Books Of Account & Instead Of Estimating The Net Profit, Additions Were Made On The Basis Of Same Books Of Account By Disallowing Expenses Under Different Heads Total Rs. 1,75,91,607/- & Addition U/S 68 R. W. S. 115Bbe Of I. T. Act For Rs. 1,32,78,833/- Which Is Contrary To The Provisions Of Law.

For Appellant: Sh. Shubham Rastogi, C.AFor Respondent: Sh. Neeraj Kumar, CIT DR
Section 143(2)Section 145(3)Section 250Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW ‘B’ BENCH, LUCKNOW BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY

JCIT(OSD), Range-10, New Delhi, C.R. Building ITO vs. Rural Electrification Corporation Ltd., Kasturba Nagar

ITA 609/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

observed that as per the above provisions of the Act, the assessee is eligible to claim 20% of the profits derived from the eligible business. The prepayment premium is received from the applicant on the loans which are repaid before its maturity, accordingly the assessee had earned Rs. 106.41 crores ... eligible for deduction. It was also submitted that the word used in the provisions of the Act that profit derived from the eligible business which is carried to the reserve account should be considered in calculating deduction under the section. The assessee relied on the decision of Hon'ble decision

JCIT(OSD), Range-10, New Delhi, C.R. Building ITO vs. Rural Electrification Corporation Ltd., Kasturba Nagar

ITA 579/DEL/2025[2021-22]Status: DisposedITAT Delhi12 Feb 2026AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

observed that as per the above provisions of the Act, the assessee is eligible to claim 20% of the profits derived from the eligible business. The prepayment premium is received from the applicant on the loans which are 7 ITA Nos.319 & 320/Del/2025 ITA Nos.577& 578/Del/2025 ITA Nos.609& 579/Del/2025 repaid before ... eligible for deduction. It was also submitted that the word used in the provisions of the Act that profit derived from the eligible business which is carried to the reserve account should be considered in calculating deduction under the section. The assessee relied on the decision of Hon'ble decision

JCIT(OSD), Range-10, New Delhi, Cr Building ITO vs. Rural Electrification Corporation Ltd., Kasturba Nagar

ITA 578/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

observed that as per the above provisions of the Act, the assessee is eligible to claim 20% of the profits derived from the eligible business. The prepayment premium is received from the applicant on the loans which are repaid before its maturity, accordingly the assessee had earned Rs. 106.41 crores ... eligible for deduction. It was also submitted that the word used in the provisions of the Act that profit derived from the eligible business which is carried to the reserve account should be considered in calculating deduction under the section. The assessee relied on the decision of Hon'ble decision

JCIT(OSD), Range-10, New Delhi, ITO C.R. Building vs. Rural Electrification Corporation Ltd., Kasturba Nagar

ITA 577/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

observed that as per the above provisions of the Act, the assessee is eligible to claim 20% of the profits derived from the eligible business. The prepayment premium is received from the applicant on the loans which are 7 ITA Nos.319 & 320/Del/2025 ITA Nos.577& 578/Del/2025 ITA Nos.609& 579/Del/2025 repaid before ... eligible for deduction. It was also submitted that the word used in the provisions of the Act that profit derived from the eligible business which is carried to the reserve account should be considered in calculating deduction under the section. The assessee relied on the decision of Hon'ble decision

Rec Limited, New Delhi vs. ACIT-10 (OSD), Delhi, New Delhi

ITA 320/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

observed that as per the above provisions of the Act, the assessee is eligible to claim 20% of the profits derived from the eligible business. The prepayment premium is received from the applicant on the loans which are 7 repaid before its maturity, accordingly the assessee had earned ... eligible for deduction. It was also submitted that the word used in the provisions of the Act that profit derived from the eligible business which is carried to the reserve account should be considered in calculating deduction under the section. The assessee relied on the decision of Hon'ble decision

Rec Limited, New Delhi vs. ACIT-10 (OSD), Delhi, New Delhi

In the result, appeals filed by the revenue in the AY 2020-21 and AY

ITA 319/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

observed that as per the above provisions of the Act, the assessee is eligible to claim 20% of the profits derived from the eligible business. The prepayment premium is received from the applicant on the loans which are 6.3 ITA Nos.319 & 320/Del/2025 ITA Nos.577& 578/Del/2025 ITA Nos.609& 579/Del/2025 repaid before ... eligible for deduction. It was also submitted that the word used in the provisions of the Act that profit derived from the eligible business which is carried to the reserve account should be considered in calculating deduction under the section. The assessee relied on the decision of Hon’ble decision