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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

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Balrampur Chini Mills Ltd, Kolkata

In the result all the four appeals of the revenue are dismissed

ITA 1082/KOL/2025[2021-22]Status: DisposedITAT Kolkata26 Aug 2025AY 2021-22

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Praveen Kishore, DR
Section 80Section 92C

wherein the said issue was decided in its favour. Sub-section (8) of section 80-IA provides that goods or services held by the eligible business should be transferred to any other business at "market value". Explanation to section 801A(8) provides for the definition of market value. The Explanation ... seen that if the assessing officer disputes the consideration for supply of any goods by the assessee as recorded in the accounts of the eligible business on the ground that it does not correspond to the market value of such goods as on the date of the transfer, then

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Balrampur Chini Mills Ltd, Kolkata

In the result all the four appeals of the revenue are dismissed

ITA 1081/KOL/2025[2020-21]Status: DisposedITAT Kolkata26 Aug 2025AY 2020-21

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Praveen Kishore, DR
Section 80Section 92C

wherein the said issue was decided in its favour. Sub-section (8) of section 80-IA provides that goods or services held by the eligible business should be transferred to any other business at "market value". Explanation to section 801A(8) provides for the definition of market value. The Explanation ... seen that if the assessing officer disputes the consideration for supply of any goods by the assessee as recorded in the accounts of the eligible business on the ground that it does not correspond to the market value of such goods as on the date of the transfer, then

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Balrampur Chini Mills Ltd, Kolkata

In the result all the four appeals of the revenue are dismissed

ITA 1080/KOL/2025[2018-19]Status: DisposedITAT Kolkata26 Aug 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Praveen Kishore, DR
Section 80Section 92C

wherein the said issue was decided in its favour. Sub-section (8) of section 80-IA provides that goods or services held by the eligible business should be transferred to any other business at "market value". Explanation to section 801A(8) provides for the definition of market value. The Explanation ... seen that if the assessing officer disputes the consideration for supply of any goods by the assessee as recorded in the accounts of the eligible business on the ground that it does not correspond to the market value of such goods as on the date of the transfer, then

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Balrampur Chini Mills Ltd, Kolkata

In the result all the four appeals of the revenue are dismissed

ITA 1079/KOL/2025[2017-18]Status: DisposedITAT Kolkata26 Aug 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Praveen Kishore, DR
Section 80Section 92C

wherein the said issue was decided in its favour. Sub-section (8) of section 80-IA provides that goods or services held by the eligible business should be transferred to any other business at "market value". Explanation to section 801A(8) provides for the definition of market value. The Explanation ... seen that if the assessing officer disputes the consideration for supply of any goods by the assessee as recorded in the accounts of the eligible business on the ground that it does not correspond to the market value of such goods as on the date of the transfer, then

Addl CIT Ltu, Mumbai vs. Bajaj Holding & Investment Ltd ( Foremerly Known As Bajaj Auto Ltd), Mumbai

In the result, appeal filed by the revenue is dismissed and appeal filed by the assessee stands partly allowed as indicated hereinabove

ITA 5510/MUM/2012[2007-08]Status: DisposedITAT Mumbai26 Aug 2025AY 2007-08

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

Section 14ASection 80

profits and gains derived by an undertaking or an enterprise from any business referred to in sub-section (4), i.e., referred to as the eligible business, there shall, in accordance with and subject to the provisions of the section, be allowed, in computing the total income of the assessee ... amount equal to 100 per cent. of the profits and gains derived from such business for ten consecutive assessment years. Deduction is given to eligible business and the same is defined in sub-section (4). Sub-section (2) provides option to the assessee to choose 10 consecutive assessment years

Shahid Iqbal, Indore vs. ITO 5(2), Indore

ITA 884/IND/2024[2016-17]Status: DisposedITAT Indore22 Aug 2025AY 2016-17

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M. Joshi

Section 143Section 246ASection 250Section 253Section 263

file the necessary documents but rather than filing the related documents he has expressed his grievance. 4.3 For any expenditure to be allowed as eligible business expenditure, it is duly of the appellant or an assessee to prove that the expenditure was incurred wholly and exclusive for the purpose

M/S Allahdad Tannery, Kanpur vs. Dy. Commissioner of Income Tax-I, Kanpur

ITA 620/LKW/2016[2004-05]Status: DisposedITAT Lucknow20 Aug 2025AY 2004-05
Section 143(1)Section 143(2)Section 801BSection 80HSection 80ISection 8O

आयकर अपीलीय अधिकरण 'बी' न्यायपीठ, लखनऊ। IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH “B”, LUCKNOW श्री कुल भारत, उपाध्यक्ष

Indian Metals and Ferro Alloys Ltd, Bhubaneswar vs. DCIT, Circle-1(1), Bhubaneswar

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 506/CTK/2024[2021-22]Status: DisposedITAT Cuttack19 Aug 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 234BSection 234CSection 270ASection 92CSection 92D

reproduced as under: “80-IA(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 ... 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 of the transfer, then, for the purposes

M/S Gvk Jaipur Expressway Private Limited, Telangana vs. PCIT 2, Jaipur

In the result, the appeal of the assessee is allowed

ITA 248/JPR/2023[2018-19]Status: DisposedITAT Jaipur19 Aug 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115Section 115JSection 143(3)Section 14ASection 263Section 36(1)(iii)Section 80

after allowing enhanced deduction u/s 80IA amounting to Rs. 2,44,59,66,041/- on account of increased in the profit of eligible business due to additions / disallowance made by the FAO in the order, under normal provisions of the Act and book profit was determined ... claimed deduction u/s 80IA on income under the head "Income from Business & Profession" and this disallowance if made will increase the profit of eligible business, which is eligible for deduction u/s 80IA. Thus it would not have any impact on the total taxable income of assessee company

Assistant Commissioner of Income Tax, Circle-1, Tiruppur vs. Prabhu Spinning Mills Private Limited, Tiruppur

ITA 435/CHNY/2025[2017-18]Status: DisposedITAT Chennai13 Aug 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:433 & 435/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 & 2017-18 Acit, Circle -1 121, Adarns Plaza, 60, Feet Road, Tiruppur - 641 602. (अपीलार्थी/Appellant) Vs. Prabhu Spining Mills Private Limited, No. 207 – 86, Mangalam Road, Karuvampalayam, Tiruppur – 641 604. Tamil Nadu. [Pan:Aabcp-0750-E] (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. Arv Sreenivasan, Cit प्रत्यर्थी की ओर से/Respondent By : Shri. T. Banusekar, Advocate. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोषणा की तारीख/Date Of Pronouncement : 13.08.2025 Per S. R. Raghunatha, Am : आदेश /Order These Two Appeals Filed By The Revenue Are Directed Against Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Chennai-16 (In Short “Id.Cit(A)”) Dated 04.10.2024 For Assessment Years 2017-18 & 2018-19 Respectively. Since Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals By The Revenue Are Being Heard Together & Disposed Of By This Consolidated Order. 2. The Appeal Of The Revenue For The Assessment Year 2017-18 Is Taken As The Lead Appeal For Adjudication Of The Issues Involved. The Only Issue Which Has Been Raised In Appeal By The Revenue Is With Regard To Determination Of Quantum Of Deduction U/S.80-Ia Of The Income Tax Act, 1961 (In Short "The Act"). :-2-:

For Appellant: Shri. ARV Sreenivasan, CITFor Respondent: Shri. T. Banusekar, Advocate
Section 143(3)Section 80Section 92C

seen that if the assessing officer disputes the consideration for supply of any goods by the assessee as recorded in the accounts of the eligible business on the ground that it does not correspond to the market value of such goods as on the date of the transfer, then ... purpose of deduction under section 80-IA, the profits and gains of such eligible business shall be computed by adopting arm's length pricing. In other words, if the assessing officer rejects the price as not corresponding to the market value of such good, then he has to compute

Assistant Commissioner of Income Tax, Tiruppur vs. Prabhu Spinning Mills Private Limited, Tiruppur

In the result all the grounds raised by the revenue for the A

ITA 433/CHNY/2025[2018-19]Status: DisposedITAT Chennai13 Aug 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:433 & 435/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2018-19 & 2017-18 Acit, Circle -1 Prabhu Spining Mills Private 121, Adarns Plaza, Vs. Limited, 60, Feet Road, No. 207 – 86, Mangalam Road, Tiruppur – 641 602. Karuvampalayam, Tiruppur – 641 604. Tamil Nadu. (अपीलाथी/Appellant) [Pan:Aabcp-0750-E] (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. Arv Sreenivasan, Cit प्रत्यथी की ओर से/Respondent By : Shri. T. Banusekar, Advocate. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोर्णा की तारीख/Date Of Pronouncement : 13.08.2025

For Appellant: Shri. ARV Sreenivasan, CITFor Respondent: Shri. T. Banusekar, Advocate
Section 143(3)Section 80Section 92C

seen that if the assessing officer disputes the consideration for supply of any goods by the assessee as recorded in the accounts of the eligible business on the ground that it does not correspond to the market value of such goods as on the date of the transfer, then ... purpose of deduction under section 80-IA, the profits and gains of such eligible business shall be computed by adopting arm's length pricing. In other words, if the assessing officer rejects the price as not corresponding to the market value of such good, then he has to compute

Atria Brindavan Power Pvt Ltd, Bangalore vs. DCIT, Central Circle-2(4), Bangalore

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

ITA 539/BANG/2025[2015-16]Status: DisposedITAT Bangalore13 Aug 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Balusamy N, JCIT (DR)
Section 10ASection 37Section 40Section 80

eligible for deduction under section 80-IA of the Act. The CBDT Circular No. 37/2016 clarifies that if the disallowance increases the eligible business income, the enhanced income is also eligible for deduction under Chapter VI-A, unless expressly prohibited. . ITA No.538&539/Bang/2025 Page 4 of 5 8.1 Although ... principles behind the circular are general. It supports the view that any disallowance, if it increases income from an eligible business, should be allowed for deduction under section 80-IA, unless barred by law. 8.2 We also rely on the decision of the Hon’ble Karnataka High Court

Atria Brindavan Power Pvt Ltd., Bengaluru vs. DCIT, Central Circle-2(4), Bengaluru

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

ITA 538/BANG/2025[2014-15]Status: DisposedITAT Bangalore13 Aug 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Balusamy N, JCIT (DR)
Section 10ASection 37Section 40Section 80

eligible for deduction under section 80-IA of the Act. The CBDT Circular No. 37/2016 clarifies that if the disallowance increases the eligible business income, the enhanced income is also eligible for deduction under Chapter VI-A, unless expressly prohibited. . ITA No.538&539/Bang/2025 Page 4 of 5 8.1 Although ... principles behind the circular are general. It supports the view that any disallowance, if it increases income from an eligible business, should be allowed for deduction under section 80-IA, unless barred by law. 8.2 We also rely on the decision of the Hon’ble Karnataka High Court

DCIT-Central Circle-1(4), Mumbai vs. Navkar Corporation Limited, Navi Mumbai

In the result, we affirm the order of the Ld

ITA 1846/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Aug 2025AY 2018-19

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

Section 115JSection 143(3)Section 32Section 80Section 801ASection 801A(4)(i)Section 801A(5)Section 801A(8)Section 80I

Total 428,17,36,000/ 7. Thereafter, ld.AO has observed that assessee has not maintained separate books of accounts in respect of eligible business activities and whereas consolidated accounts maintained by the assessee for both eligible and illegible units. In response to the show-cause notice, assessee has duly submitted ... accounts and consolidated balance-sheets/P&L account on record/no details being there on record as to what are the activities attributable to the eligible business and what are the activities attributable to the ineligible unit, deduction u/s 801A(4)(i) has to be computed on the basis

Bioagile Therapeutics Private Limited, Bengaluru vs. Income Tax Officer, Ward-5(2)(1), Bangalore

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

ITA 376/BANG/2025[2018-19]Status: DisposedITAT Bangalore06 Aug 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmedassessment Year : 2018-19

For Appellant: Smt. Pratibha R, Ld. Advocate
Section 143(3)Section 250Section 270ASection 270A(3)Section 80Section 80I

certificate issued by the Inter Ministerial Board and is not valid for availing tax benefits / deduction u/s. 80IAC as a certificate of eligible business from Inter Ministerial Board (IMB) was required and recognition certificate issued by the DPIIT was not sufficient. However, the Assessee had not submitted a copy ... certificate of eligible business issued by IMB and without aforesaid certificate, it would not be possible to allow the deduction claimed u/s. 80IAC of the Act for the AY 2018-19. In the absence of supporting document, the assessee’s claim of deduction u/s. 80IAC

ACIT, Cir-1(1), Rajkot vs. Shri Rajkot District Co Operative Bank Ltd, Rajkot

The appeal of the revenue is dismissed

ITA 188/RJT/2024[2015-16]Status: DisposedITAT Rajkot05 Aug 2025AY 2015-16

Bench: Dr. Arjun Lal Saini. & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.188/Rjt/2024 िनधा"रणवष"/ Assessment Year: (2015-16) (Hybrid Hearing) Assistant Commissioner Of Income- Vs. Rajkot District Co-Operative Bank Tax, Circle-1 (1), Rajkot Limited Room No.502, Aayakar Bhawan, Jilla Bankbhavan, Kasturba Road, Race Course Ring Road, Rajkot- Opp: Chaudhary High School, 360001 Rajkot 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaar0564K (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr : 09/06 /2025 Date Of Hearing Date Of Pronouncement : 05/08 /2025

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR
Section 143(3)Section 36(1)Section 36(1)(viii)

deduction u/s 36(1) (viii) at Rs.2,62,50,000/-. The A.O. was not satisfied with the method of computation of profit of the Eligible Business adopted by the appellant. As per the appellant, profit of the Eligible Business (provision of long-term finance for construction or purchase of houses ... claim deduction u/s 36(1) (viii) of Rs. 3,75,00,000/- of the Act.The working by the appellant of the profit of the Eligible Business was not accepted by the AO for the following reasons: (a) There has been a gross error in the allocation of expenditure

Dy..C.I.T., Bangalore vs. M/S State Bank of Mysore, Bangalore

In the result, the appeal of the Revenue Ground-3 is dismissed

ITA 683/BANG/2015[2010-11]Status: DisposedITAT Mumbai05 Aug 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjee

For Appellant: Shri Ketan Ved & Ninad PatadeFor Respondent: Shri P.C. Chhotaray, Spl. Counsel
Section 143(3)Section 250Section 36(1)(vii)Section 36(1)(viia)Section 41(1)Section 41(4)

viii) of the Act. f) The learned CIT(A) ought to have observed that the Appellant has been computing the 'profits from eligible business for the purpose of section 36(1)(viii) based on the turnover (interest income) of the Appellant, which has been accepted by the revenue authorities ... Ld.AR submitted that deduction under section 36(1)(viii) of the Act is allowed in respect of the profits derived from the eligible business computed under the head Profits and Gains from Business and Profession. During the year under consideration the assesse transferred R.60,42,30,000/- to Special Reserve

State Bank of Mysore, Bangalore vs. JCIT, Bangalore

In the result, the appeal of the Revenue Ground-3 is dismissed

ITA 660/BANG/2015[2010-11]Status: DisposedITAT Mumbai05 Aug 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeestate Bank Of India Vs Joint Commissioner Of Income-Tax, (Erstwhile State Bank Of Large Tax Payers Unit, Bangalore Mysore Prior To Merger) Local Head Office Compliance Department, 4Th Floor, 65, St. Marks Road, Bangalore-560 001 Pan: Aaccs0155P Appellant Respondent Deputy Commissioner Of Vs State Bank Of Mysore Income-Tax, Ltu, Circle-1, Head Office, Finance & Accounts Bangalore Department, Kg Road, Bangalore- 560 009 Pan: Aaccs0155P Appellant Respondent

For Appellant: Shri Ketan Ved & Ninad PatadeFor Respondent: Shri P.C. Chhotaray, Spl. Counsel
Section 143(3)Section 250Section 36(1)(vii)Section 36(1)(viia)Section 41(1)Section 41(4)

viii) of the Act. 1) The learned CIT(A) ought to have observed that the Appellant has been computing the 'profits from eligible business for the purpose of section 36(1)(viii) based on the turnover (interest income) of the Appellant, which has been accepted by the revenue authorities ... Ld.AR submitted that deduction under section 36(1)(viii) of the Act is allowed in respect of the profits derived from the eligible business computed under the head Profits and Gains from Business and Profession. During the year under consideration the assesse transferred R.60,42,30,000/- to Special Reserve

Assistant Commissioner of Income Tax, Circle- 1(1)(1), Dehradun vs. Thdc India Limited, Tehri

In the result, the appeal of the Revenue is dismissed as above

ITA 120/DDN/2024[2020-21]Status: DisposedITAT Dehradun31 Jul 2025AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 115JSection 7Section 80I

claimed deduction under section 80IA of the Income Tax Act, 1961, had no direct nexus but only incidental or attributable to the assessee's eligible business activities of power generation and distribution that qualify for deduction under section 80IA of the Income Tax Act, 1961. 1 THDC India ... excess provisions written back and late payment surcharges on debtors on the reasoning that such income has not any direct nexus with the eligible business activities of the assessee. 4. Before us, the Ld. Senior Departmental Representative (‘Sr. DR’) submitted that the core issue in dispute; i.e. the disallowance

Gruh Finance Ltd., Ahmedabad vs. The DCIT, Circle-2(1)(1), Ahmedabad

Appeal is dismissed

ITA 1228/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2011-12

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

total deduction claimed u/s.36(1)(viii), the amount recoverd as bad debts was cannot be held as income derived from the eligible business of Long Term Housing Finance. The Ld.CIT(A) relied upon the decision of the Tribunal in own case of assessee ... No.1295/Ahd/2009, dated 17/08/2006, has granted deduction u/s.36(1)(viii) of the Act holding the recovery of bad debts as derived from the eligible business of the assessee. 16. The Ld.DR could not show any distinguishing case-laws. In view of this, there is no merit in this ground of Revenue