Eligible Undertaking

An income, so as to be characterized as `derived from’ an undertaking u/s 80-IA, should directly result from its operations

In order to be covered within the expression derived from it is sine qua non that the relation between the income and source must be that of the first degree Where the relation between income and source slips from first to second degree, income stands excluded from the scope of expression derived from and may fall within the purview of attributable to.
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Interest on late payment from customers against supply of goods is eligible for deduction u/s 80-IA

Gujarat High Court, when interest is paid on delayed payment, it can be treated as higher sale price which is converse situation to offering of cash discount because the transaction remains the same and there is no distinction $s to the source. Looking from' this angle, the interest becomes part of the hire sale price and is clearly derived from the sales made and is not divorced therefrom. It is, thus, the direct result of the sale of goods and the income k derived from..
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Amount eligible for tax holiday is specific to each undertaking of the Taxpayer: Chennai Special Bench

whether the losses of an undertaking of the Taxpayer which is not eligible for tax holiday (Non-eligible Undertaking), are required to be set off against the profits of another undertaking of the Taxpayer which is eligible for tax holiday (Eligible Undertaking). The SB held that the amount eligible for tax holiday was specific to each undertaking of the Taxpayer. Further, for the purpose of determining the amount eligible for tax holiday under the ITL, the losses of a No..
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