“Section 10(2)(ia)”
The decision most relied on for Section 10(2)(ia) is HDFC Bank Ltd. v. DCIT (383 ITR 529), cited in 408 judgments on BharatTax.
Leading authorities on Section 10(2)(ia)
Where an assessee has sufficient interest-free funds, investments yielding exempt income are presumed to be made out of such funds, precluding disallowance of related interest expenditure under section 14A.
The reasonableness of an expenditure for business purposes must be assessed from the businessman's perspective, not the revenue's, and the primary motive to earn income directly is not a prerequisite for its admissibility as a deduction.
The activity of cutting jumbo roll films into flat and small rolls in desired sizes is considered manufacture or production for the purposes of the Income-tax Act.
There can be no presumption that an assessee must have incurred expenditure to earn tax-free income. Disallowance under section 14A requires actual expenditure, not notional or estimated amounts.
Interest income earned by an assessee on fixed deposits and other interest income is eligible for deduction under Section 80-IA of the Income-tax Act, 1961.
For an activity to be considered 'manufacture', it must result in a transformation where a new and different article emerges with a distinctive name, character, or use.
Deductions under Chapter VI-A of the Income Tax Act, such as Section 80-IA, are to be calculated and allowed with reference to the assessee's gross total income, not just business income.
Profits and gains from scraps resulting from a manufacturing process are eligible for deduction under Section 80IC of the Income Tax Act.