Ownership not necessary for consideration of service charges as profits & gains from industrial undertaking

key issue is whether the ownership of an industrial undertaking is a relevant factor for the purposes of construing the provisions of Section 80-I of  the said Act. We find ourselves to be in agreement with the submission made by Mr Ganesh that Section 80-I does not speak of the ownership of an industrial undertaking.

On a plain reading of Section 80-I(1) of the said Act, it is apparent that the first question is – what is the gross total income of an assessee ? The next question is: does it include any profits or gains der

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