Section 80-I of the Income Tax Act
The decision most relied on for Section 80-I is Nirma Industries Ltd. v. DCIT (283 ITR 402), cited in 136 of the 128 judgments on BharatTax that turn on this section.
Leading authorities on Section 80-I
Interest charged on delayed realization of sale proceeds constitutes business income and is eligible for deduction under Section 80-I of the Income-tax Act.
Extraction and processing of iron ore constitutes "production" for the purpose of claiming tax benefits like investment allowance under Section 32A and additional depreciation under Section 32(1)(iia), even if it does not amount to "manufacture".
Interest charged on late realization of sale proceeds is treated as business income and is eligible for deduction under Section 80-I.
The case clarified that activities like cutting marble blocks into slabs can constitute 'manufacture' for excise purposes, a principle relevant to understanding 'production' under Section 80-IA of the Income Tax Act, even if the earlier judgment did not explicitly interpret 'production'.
Income from service charges, maintenance revenue, and lease rent can be considered as derived from the main business activity of the assessee, provided there is a direct nexus. Such income may not be treated as income derived from an industrial undertaking for the purpose of Section 80-I.
The extraction and processing of iron ore, even if not amounting to the manufacture or production of an article or thing, can constitute 'production' for the purposes of claiming deductions under Section 80-IA and depreciation under Section 32-A of the Income Tax Act, 1961.
