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Scientific Publishing Services Pvt. ... vs Department Of Income Tax

In appeal, the Tribunal has relied upon a decision of its Special Bench in the case of Scientific Atlanta Vs. ACIT1 in which it has been emphasised that the provision contained in Section 10A is not an exemption but a deduction under Chapter III. Following that decision, the Tribunal held that the deduction under Section 10A in respect of the allowable unit under Section 10A has to be allowed before setting off brought forwarded losses of a non 10A unit.
Income Tax Appellate Tribunal - Chennai Cites 18 - Cited by 0 - Full Document

Salt Lake Shiksha Sadan, Kolkata vs Ito(Exemp.)Ward 1(3), Kolkata on 12 June, 2023

3. The ld. counsel for the assessee has submitted that the exercise of revision jurisdiction by the ld. PCIT in this case is not justified because the issue being one is a debatable issue. The ld. counsel in this respect apart from relying on the decisions as mentioned above, has further relied upon the decision of ITAT, Kolkata in the case of Vidya Bharati Society For Education & Scientific Advancement vs. ACIT in ITA Nos.2397&2398/Kol/2017 dated 10.01.2020, Panchjanya Trust vs. ITO in ITA No.1841/Kol/2017 dated 01.10.2019 and the decision of Hon'ble Karnataka High Court in the case of DCIT vs. Children's Education Society in ITA No.1078 of 2006 and Ors. to submit that in the aforesaid decisions the funds received for development purpose have been held to be originally treated towards corpus fund of the recipients and it has been held that the same were not the revenue receipt.
Income Tax Appellate Tribunal - Kolkata Cites 9 - Cited by 0 - Full Document
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