S. 80-IC : Special group says – Special terms in respect out of specific endeavors – Determining Officer perhaps not rationalized inside doubting deduction u/s 80IC away from recently based tool simply to your foundation out of use out-of electricity in various devices of Assessee given that several factors can be subscribe to the increased payouts.

Held by High Court one to, there is no need to restrict the fresh results of Appellate Bodies favoring Assessee, since several things can join the elevated winnings and you may abreast of attention of such numerous situations that happen to be besides pleaded, however, produced good-by the brand new Assessee to summarize there is actually no-good floor so you’re able to refuse the newest deduction under Section 80IC of the new Act only based on use of fuel in certain units of Assessee. (TA Zero. 62 of 2014 and you may 13 from 2015 dt. 29-09-2020) (AY 2006-07 and you can AY 2007-08). CIT .v. Borkar Packaging (P.) Ltd. (2020) 121 taxmann 167 / 320 CTR 792 (Bom) (HC)

S. 90: Twice tax rescue – Assessee – Providers becoming a taxation citizen out of Singapore is approved to the benefits of Asia-Singapore taxation treaty regarding business regarding offers inside the Indian subsidiary – LOB clause isn’t appropriate as such profit is pursuant to legitimate business restructuring and you will MNC’s passion to be a financial investment holding business is a beneficial bonafide organization passion – And therefore, zero money progress at discount of offers away from Indian subsidiary because of the a good Singapore holding money providers. Continue reading “Part 115JB wasn’t appropriate on assessee because out-of Factor 3 so you can area 115JB”