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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

Lotus Footwear Enterprises Limited-India Branch, Tiruvannamalai vs. DCIT, International Tax 1(2), Chennai

In the result all the four appeals of the assessee are allowed

ITA 800/CHNY/2022[2019-2020]Status: DisposedITAT Chennai25 Sept 2025AY 2019-2020

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. Sriram Seshadri, C.A. &For Respondent: Ms. Pavuna Sundari, C.I.T
Section 10A

undertaking referred to in section 80-IA.” Section 80IA of the Act “(8) Where any goods or services held for the purposes of the eligible business are transferred to any other business carried on by the assessee, or where any goods or services held for the purposes ... A.No.:20 /Chny/2021 & ITA Nos. 798, 799 & 800/Chny/2022 other business carried on by the assessee are transferred to the eligible business and, in either case, the consideration, if any, for such transfer as recorded in the accounts of the eligible business does not correspond to the market value of such

Lotus Footwear Enterprises Limited-India Branch, Tiruvannamalai vs. DCIT, International Tax 1(2), Chennai

ITA 799/CHNY/2022[2018-2019]Status: DisposedITAT Chennai25 Sept 2025AY 2018-2019

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./It(Tp)A No.: 20/Chny/2021 &

Section 10ASection 115J

undertaking referred to in section 80-IA.” Section 801A of the Act “(8) Where any goods or services held for the purposes of the eligible business are transferred to any other business carried on by the assessee, or where any goods or services held for the purposes of any other ... business carried on by the assessee are transferred to the eligible business and, in either case, the consideration, if any, for such transfer as recorded in the accounts of the eligible business does not correspond to the market value of such goods or services as on the date

Lotus Footwear Enterprises Limited-India Branch, Tiruvannamalai vs. DCIT, International Tax 1(2), Chennai

In the result all the four appeals of the assessee are allowed

ITA 798/CHNY/2022[2017-2018]Status: DisposedITAT Chennai25 Sept 2025AY 2017-2018

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. Sriram Seshadri, C.A. &
Section 10A

undertaking referred to in section 80-IA.” Section 801A of the Act “(8) Where any goods or services held for the purposes of the eligible business are transferred to any other business carried on by the assessee, or where any goods or services held for the purposes ... A.No.:20 /Chny/2021 & ITA Nos. 798, 799 & 800/Chny/2022 other business carried on by the assessee are transferred to the eligible business and, in either case, the consideration, if any, for such transfer as recorded in the accounts of the eligible business does not correspond to the market value of such

DCIT Central Circle 3(2), Mumbai, Air India vs. Aarti Industries Limited, Mumbai

In the result, the appeal is dismissed

ITA 4869/MUM/2023[2015-2016]Status: DisposedITAT Mumbai25 Sept 2025AY 2015-2016

Bench: Shri Saktijit Dey & Shri Girish Agrawaldy. Cit, Central Circle-3(2) Aarti Industries Limited R. No. 1913, 19Th Floor, 71, Udyog Kshetra, 2Nd Floor, Air India Building, Nariman Point, Vs. Mulund Goregaon Link Road, Mumbai-400 021 Mulund (W), Mumbai-400 080 Pan/Gir No. Aabca 2787 L (Appellant) : (Respondent) Appellant By : Shri Vijay Mehta Respondent By : Shri Rajesh Kumar Yadav Date Of Hearing : 12.08.2025 Date Of Pronouncement : 25.09.2025 O R D E R Per Saktijit Dey: This Is An Appeal By The Revenue, Against The Order Dated 30.10.2023 Of Learned Commissioner Of Income Tax (Appeals), Mumbai (‘Ld.Cit(A) For Short), Pertaining To The Assessment Year (A.Y.) 2015-16. 2. Ground No. 1 In The Appeal Reads As Under: 1. On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred In Deleting The Disallowances Made By The A.O. To Restrict The Deduction U/S. 80Ia Of The Act Despite The Fact That The Issue Has Not Attained Finality & Pending For Adjudication Before The Hon'Ble Supreme Court? – Rs.396,81,798/- 3. Briefly The Facts Are, The Assessee Is A Resident Corporate Entity Engaged In Manufacturing & Sale Of Chemicals, Fertilizers & Intermediaries. For Such Manufacturing Activity, The Assessee Has Set Up A Plant At Plot No. 801/23, Gidc, Phase-Iii

For Appellant: Shri Vijay MehtaFor Respondent: Shri Rajesh Kumar Yadav
Section 133(6)Section 80I

Commission payments 5,00,34,000 Payment of Professional fees 6,48,182 Payment of Salary 21,44,261 Sale of power from eligible business units to non- 181,65,20,754 eligible business units of the company Total 199,04,41,170 6. Details and information requested were furnished

Pankaj Kumar Mittal, Dholpur vs. Income Tax Officer Ward 4 Bharatpur, Bharatpur

In the result, stands allowed

ITA 393/JPR/2025[2018-2019]Status: DisposedITAT Jaipur24 Sept 2025AY 2018-2019
For Appellant: Shri Rahul Pandya, AdvFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 144ASection 148Section 271ASection 44A

Refer Page -18) The provisions of section 44AD are quite unambiguous to the effect that in case of an eligible business based on the gross receipts/total turnover, the income under the head 'profits & gains of business' shall be deemed to be at the rate of 8 per cent

Deputy Commissioner of Income Tax, Circle 4(2), New Delhi, I.P.Estate vs. Bird Worldwide Flight Service (India) Private Limited, Connaught Place, New Delhi

ITA 2779/DEL/2023[2017-18]Status: DisposedITAT Delhi24 Sept 2025AY 2017-18

Bench: Shri Mahavir Singh & Shri Amitabh Shukla

Section 115JSection 250Section 80I

purposes of Section 80-IA of the Act." 10. The Assessing Officer on second aspect that the assessee was not doing the eligible business as prescribed under Section 80IA(4) of the Act i.e., infrastructure development since assessee had entered into an agreement with DIAL/CIAL for undertaking ground handling services

Shri Sant Narhari Nagari Shahkar Pat Sanstha Maryadit, Bhandra vs. ITO, Ward -2, Bhandara

In the result, Assessee’s appeal is allowed in part for statistical purposes

ITA 431/NAG/2024[2017-18]Status: DisposedITAT Nagpur23 Sept 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryshri Sant Narhari Nagari Ito, Ward-2, Bhandara Shahkar Pat Sanstha Maryadit, R.No. 1/2 Nagar Vs. Palika Shivaji Chowk, Pauni, Bhandra-441910. Pan: Aakts 3987 N (Appellant) (Respondent)

For Appellant: Shri Kapil Hiranji, Ld. AdvocateFor Respondent: Shri Surjit Kumar Saha, Ld. Sr.D.R
Section 194HSection 250Section 40Section 80ASection 80A(5)Section 80PSection 80P(5)

liability existed for recipients and without prejudice, disallowance, if any, then it should be restricted and considered as an eligible business income deductible u/sec. 80P of the Act. Thus, on the aforesaid analyzation, this Court is of the 5 considered view that the addition is unsustainable, hence the addition/disallowance ... alternatively allowable u/sec. 36(1)(viia) of the Act. The Assessee further submitted that without prejudice, if any, such addition forms part of eligible business income for 80P deduction. 10. The AO has made the addition of 2,28,435/- by considering that the Assessee society was duty bound

Sree Narayana Guru Cooperative Thrift and Credit Society Limited, Delhi vs. Commissioner of Income Tax (Appeals), Civic Centre

Appeal is allowed in above terms

ITA 4783/DEL/2025[2018-19]Status: DisposedITAT Delhi22 Sept 2025AY 2018-19

Bench: Sh. Satbeer Singh Godaraita No. 4783/Del/2025 : Asstt. Year : 2018-19 Sree Narayana Guru Cooperative Vs Cit(A)/Nfac Thrift & Credit Society Ltd., Income Tax Officer, Sree Narayana Kendra, Rb2, Ward-43(6), Pocket-3, Sector-7, D, Dwarka, New Delhi-110002 Sector-6, New Delhi-110075 (Appellant) (Respondent) Pan No. Aacas8347K Assessee By: None Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 22.09.2025 Date Of Pronouncement: 22.09.2025 Order This Assessee’S Appeal For Assessment Year 2018-19, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1078029340(1) Dated 30.06.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 143(3)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. I find no merit in the Revenue’s instant vehement arguments in light of (2024) 164 taxmann.com

Sh. Hari Prakash Gupta, Jaipur vs. ITO, Ward-1(2), Jaipur

The appeal stands allowed

ITA 772/JPR/2025[2010-11]Status: DisposedITAT Jaipur18 Sept 2025AY 2010-11

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 271(1)(c)Section 37(1)Section 44A

receipt minus expenditure. The assessee has not maintained the books of account. Section 44AD of the Act provides that an eligible assessee engaged in eligible business shall be assessed at 8% of the total turnover or gross receipts. Assessee being an Individual is an eligible assessee and he is carrying ... eligible business which includes any business except the business of plying, hiring or leasing goods carriage and whose total turnover or gross receipt does not exceed Rs.40 lacs. Hence at the most 8% of Rs.13,90,000/- i.e. Rs.1,11,200/- can be assessed to tax. For this reliance

Sh. Hari Prakash Gupta, Jaipur vs. ITO, Ward-1(2), Jaipur

The appeal stands allowed

ITA 771/JPR/2025[2010-11]Status: DisposedITAT Jaipur18 Sept 2025AY 2010-11
For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 271(1)(c)Section 37(1)Section 44A

receipt minus expenditure. The assessee has not maintained the books of account. Section 44AD of the Act provides that an eligible assessee engaged in eligible business shall be assessed at 8% of the total turnover or gross receipts. Assessee being an Individual is an eligible assessee and he is carrying ... eligible business which includes any business except the business of plying, hiring or leasing goods carriage and whose total turnover or gross receipt does not exceed Rs.40 lacs. Hence at the most 8% of Rs.13,90,000/- i.e. Rs.1,11,200/- can be assessed to tax. For this reliance

ACIT, New Delhi vs. M/S Nuwave E Solutions (P) Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 3676/DEL/2011[2007-08]Status: DisposedITAT Delhi12 Sept 2025AY 2007-08

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2007-08] Acit, Vs M/S. Nuwave E Solutions (P) Circle-13(1), Ltd., 3Rd Floor, District Centre, New Delhi Dda Building, Nehru Place, New Delhi. Pan-Aabcn5790Q Appellant Respondent Appellant By Shri Pravin Rawal, Cit Dr Respondent By Dr. Rakesh Gutpa, Adv., Shri Saksham Agarwal, Ca, Shri Somil Agarwal, Adv. & Shri Deepesh Garg, Adv. Date Of Hearing 26.06.2025 Date Of Pronouncement 12.09.2025 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By The Revenue Against The Order Dated 15.03.2011 Passed By Ld. Commissioner Of Income Tax (Appeal)-Xvi, New Delhi [“Cit(A)”, In Short] Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 31.12.2010 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2007-08. 2. Brief Facts Of The Case Are That Assessee Is A Company & E- Filed Its Return Of Income On 30.08.2007, Declaring Total Income Of Inr 1,45,48,453/-. The Said Return Was Revised On 20.08.2008, Declaring The Same Income As Was Declared The Return Of Income Filed U/S 139(1). The Case Of The Assessee Was Selected For Scrutiny & Various Queries Were Raised Which Were Replied By The Assessee. The Assessee Is Engaged In The Business Of Development & Export Of Software & 100% Eou Registered With Director Software Technology Park Of India In Terms Of Registration Certificate Dated 31.03.1999. The Major Shareholder In The Assessee Company Is Shri Anil Gutpa Who Is Having 99% Shareholding & Is Taking Substantial Interest In Day-To-Day Affairs Of The Assessee & Also In Its Associate Enterprises (“Ae”) At Us Who Is The Sole Buyer Of The Software Developed By The Assessee.

Section 10Section 10ASection 139(1)Section 143(3)Section 250Section 40Section 801A

gain on account of currency fluctuation of INR 1,23,33,934/- by holding the same being not earned from the eligible business. 4. Besides this, AO made the disallowance of INR 3,55,47,260/- by invoking the provision of section

Calories Count, Jalandhar vs. Deputy Commissioner of Income Tax Central Circle-1, Jalandhar

In the result, the appeal filed by the assessee is partly allowed as indicated

ITA 43/ASR/2024[2019-20]Status: DisposedITAT Amritsar08 Sept 2025AY 2019-20

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Y. K. Sud, C.A
Section 133ASection 142(1)Section 143(2)Section 143(3)Section 234ASection 250Section 270ASection 44A

authentic book figures produced by the assessee and has already upheld the determination of gross sales of the assessee from carrying out of an eligible business u/s 44AD(6)(b)(ii) at Rs.1.87 crores, we direct the AO to calculate the business profit @ 8% ( eight percentage of Rs.1.87 crores ), (instead

Akry Organics Private Limited, Mumbai vs. Income Tax Officer Central Circle 1(1)(1), Mumbai

In the result, we allow the claim of the assessee for deduction under section 80-IA(4) to the extent of ₹17,40,75,413/-, as made in the revised return of income

ITA 3014/MUM/2025[2021-22]Status: DisposedITAT Mumbai04 Sept 2025AY 2021-22

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 139(5)Section 143(1)Section 80

assessee claimed deduction under section 80-IA to the tune of ₹17,40,75,413/– being 100% of the profits derived from the said eligible business. 3.1. To comply with the requirement of section 80-IA(7), the assessee caused the accounts of the undertaking to be audited

Ramesh Bhatia (HUF), New Delhi vs. ITO, Ward- 42(5), New Delhi

Appeal of the assessee is dismissed

ITA 7766/DEL/2019[2013-14]Status: DisposedITAT Delhi03 Sept 2025AY 2013-14

Bench: Shri Mahavir Singh

Section 143(3)Section 80I

observing as under:- “It is pertinent to note here that as per sub-section (3) of 80ID, the deduction is not available to the eligible business if it is formed by the splitting up, or the reconstruction, of a business already in existence as well as when the eligible business

Ramesh Bhatia (HUF), New Delhi vs. ITO, Ward- 41(5), New Delhi

Appeal of the assessee is dismissed

ITA 302/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Sept 2025AY 2014-15

Bench: Shri Mahavir Singh

Section 143(3)Section 80I

observing as under:- “It is pertinent to note here that as per sub-section (3) of 80ID, the deduction is not available to the eligible business if it is formed by the splitting up, or the reconstruction, of a business already in existence as well as when the eligible business

M/S Kanak Vrindavan Resorts Limited, Jaipur vs. Income Tax Officer, Ward 6(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 543/JPR/2025[2016-17]Status: DisposedITAT Jaipur02 Sept 2025AY 2016-17

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT
Section 143(1)(a)Section 143(2)Section 143(3)Section 145Section 37

disallowance could be made only on the basis of some valid material and in absence thereof, the expenditure so claimed is an eligible business expenditure in terms of the provisions of section 37(1) of the Income tax Act, 1961. The provisions as contained in sub-section (1) of section

Secretary, Co-Operative Cane Development Union Ltd, Najibabad, District-Bijnor vs. Assesment Unit, Income Tax Department, North Block New Delhi

Appeal is allowed

ITA 79/DEL/2025[2022-23]Status: DisposedITAT Delhi28 Aug 2025AY 2022-23

Bench: Sh. Satbeer Singh Godara & Sh. Naveen Chandra

For Appellant: Ms. Gurneet Kaur, AdvFor Respondent: Sh. Rajesh Mahajan, Sr. DR
Section 143(3)Section 80PSection 80P(2)

present instance received from parking of surplus funds in fixed deposits with scheduled/nationalized banks could not be held as “derived” from an eligible business activity under section 80P(2); and, therefore, the same deserves to be assessed as income from “other” sources only. 4. Mr. Mahajan also quotes

ACIT, Circle-3(2), New Delhi vs. Asian Consolidated Inds.Ltd), Rewari

In the result, all the 03 appeals filed by the Revenue stand dismissed in the aforesaid manner

ITA 7501/DEL/2018[1995-96]Status: DisposedITAT Delhi27 Aug 2025AY 1995-96

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Ita No. 6218/Del/2017 (Asstt. Year 1994-95) & Dcit, Circle-3(2), New Delhi Vs. M/S Asian Consolidated Industries Ltd., 96Th Mile Stone, Delhi-Jaipur Highway, Village-Bawal, Distt.- Rewari, Haryana (Pan: Aaaca5887A) (Appellant) (Respondent) Assessee By : Sh. Ved Jain, Adv. & Sh. Ayush Garg, Ca Department By : Ms. Monika Singh, Cit-Dr Date Of Hearing 20.08.2025 Date Of Pronouncement 27.08.2025 Order Per Krinwant Sahay, Am:

For Appellant: Sh. Ved Jain, Adv. & Sh. Ayush Garg, CAFor Respondent: Ms. Monika Singh, CIT-DR
Section 264

amounting to Rs.2,17,38,272/- in absence of books of accounts and other evidences to justify that the income was derived from eligible business which is statutory requirement for claim of deduction u/s 80HH and 80l of the Income-tax Act, 1961. 4 4. The appellant craves leave

DCIT, Circle-3(2), New Delhi vs. Asian Consolidated Inds.Ltd), Rewari

In the result, all the 03 appeals filed by the Revenue stand dismissed in the aforesaid manner

ITA 4514/DEL/2018[1993-94]Status: DisposedITAT Delhi27 Aug 2025AY 1993-94

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Ita No. 6218/Del/2017 (Asstt. Year 1994-95) & Dcit, Circle-3(2), New Delhi Vs. M/S Asian Consolidated Industries Ltd., 96Th Mile Stone, Delhi-Jaipur Highway, Village-Bawal, Distt.- Rewari, Haryana (Pan: Aaaca5887A) (Appellant) (Respondent) Assessee By : Sh. Ved Jain, Adv. & Sh. Ayush Garg, Ca Department By : Ms. Monika Singh, Cit-Dr Date Of Hearing 20.08.2025 Date Of Pronouncement 27.08.2025 Order Per Krinwant Sahay, Am:

For Appellant: Sh. Ved Jain, Adv. & Sh. Ayush Garg, CAFor Respondent: Ms. Monika Singh, CIT-DR
Section 264

amounting to Rs.2,17,38,272/- in absence of books of accounts and other evidences to justify that the income was derived from eligible business which is statutory requirement for claim of deduction u/s 80HH and 80l of the Income-tax Act, 1961. 4 4. The appellant craves leave

DCIT, Circle-3(2), New Delhi vs. Asian Consolidated Inds.Ltd), Rewari

In the result, all the 03 appeals filed by the Revenue stand dismissed in the aforesaid manner

ITA 6218/DEL/2017[1994-95]Status: DisposedITAT Delhi27 Aug 2025AY 1994-95

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Ita No. 6218/Del/2017 (Asstt. Year 1994-95) & Dcit, Circle-3(2), New Delhi Vs. M/S Asian Consolidated Industries Ltd., 96Th Mile Stone, Delhi-Jaipur Highway, Village-Bawal, Distt.- Rewari, Haryana (Pan: Aaaca5887A) (Appellant) (Respondent) Assessee By : Sh. Ved Jain, Adv. & Sh. Ayush Garg, Ca Department By : Ms. Monika Singh, Cit-Dr Date Of Hearing 20.08.2025 Date Of Pronouncement 27.08.2025 Order Per Krinwant Sahay, Am:

For Appellant: Sh. Ved Jain, Adv. & Sh. Ayush Garg, CAFor Respondent: Ms. Monika Singh, CIT-DR
Section 264

amounting to Rs.2,17,38,272/- in absence of books of accounts and other evidences to justify that the income was derived from eligible business which is statutory requirement for claim of deduction u/s 80HH and 80l of the Income-tax Act, 1961. 4 4. The appellant craves leave