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Commissioner Of Income Tax-I vs M/S Reliance Energy Ltd (Formerly Bses ... on 28 April, 2021

The lease rental income, on the lease of the house property thereto, would thus, in our view, notwithstanding the use of the words 'profits and gains' and 'business' in section 80-IAB(1), qualify to be eligible for deduction there-under. That is, the lease rental is within the contemplation of the profits derived by a developer of a SEZ from the 'business' of developing it, eligible for deduction u/s. 80-IAB. It is in fact this that forms the basis of the decisions in Coimbatore Hitech Infrastructure (P.) Ltd. (supra) and Global Tech Park Pvt. Ltd. (supra). The head of income under which the said income is assessable, which is on the basis of the source - from amongst the specified sources under the Act, most appropriate for the said income, so that it is not assessable as business income but as 20 ITA Nos.8524 to 8526/Del./2019 income from house property, would not be a limiting or debilitating factor. We decide accordingly, and the assessee succeeds qua it's alternate ground, i.e., in principle."
Supreme Court of India Cites 20 - Cited by 25 - L N Rao - Full Document

The Commissioner Of Income Tax Delhi-Iv vs Dlf Commercial Developers Limited on 11 July, 2013

"That the matter needs to be examined with reference to case records and paperbook from field formation which have been requested for submitting before Hon'ble ITAT and are awaited for effective representation on varied GOA raised by Revenue in light of decision of Delhi High Court in 92 taxmann.com 10 in the case of CIT vs DLF Commercial Developers dated 22.02.2018 (ITA 507/2014,563/2015,610/2017) wherein it is stated that " ... 10. This Court is of the opinion that the ITAT's decision merely reproduced the CIT(A)'s judgment and has not analysed independently, in either of the AYs, the applicability of Section 80IAB towards the deductions claimed in the light of the transactions reported and the documents disclosed. Furthermore, those facts have also to be analysed in the light of the provisions of SEZ Act, 2005, which the ITAT has not independently done. For these reasons, the impugned orders of the ITAT are set-aside and are remitted for fresh consideration by the ITAT in accordance with law. All rights and contentions of the parties are reserved ... "
Delhi High Court Cites 23 - Cited by 56 - S R Bhat - Full Document
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