Section 80HH of the Income Tax Act
The decision most relied on for Section 80HH is CIT v. Sterling Foods (237 ITR 579), cited in 311 of the 102 judgments on BharatTax that turn on this section.
Leading authorities on Section 80HH
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.
Laws relating to economic activities are viewed with greater latitude than laws touching civil rights, allowing the legislature "some play in the joints" to deal with complex problems without rigid formulas.
The courts will not interfere with the deletion of additions for gifts if the genuineness of the gifts is doubted solely on the alleged failure of the assessee to establish a relationship between the donor and the donee.
