admissibility of relief under Section 80HHC , under Section 80-O , under Section 80J etc., requires the filing of report of certificate, wherein the quantum ... deduction of income-tax under Section 80-O . The learned DR, thus, argued that relief under Section 80RR would be available to the assessee
that the appellant is not an actor within the meaning of Section 80RR of the IT Act and hence not entitled to deduction claimed under ... Section 80RR of Rs. 6,87,198 by the appellant and learned CIT(A) erred in confirming the same.
2. The learned ITO has erred
assessing officer framed the assessment under section 143(3) and allowed the deduction under section 80RR amounting to Rs. 45,109 claimed by the assessee ... which is a requisite condition for allowance of deduction under. Section 80RRA . Under section 80RR , professional income can be derived by exercising profession in India
issue, i.e., denial of deduction by the Revenue authorities under Section 80RR of the IT Act in respect of income ... Section 80HH , etc., the mandatory requirement is that the income should be derived from an industrial undertaking. On the other hand, under Section 80RR
Audit Report u/s. 44AB . The
return was processed u/s. 143(1) at the returned
income. Notice u/s. 143(2) was issued ... benefit of that section."
15.4. The perusal of the above said circular clearly shows that
section 80RR is a beneficial provision intended to provide
holding that the appellant is not eligible for deduction under Section 80RR of the IT Act, 1961 and the reasons assigned by him in this ... under the relevant section. In the case of Harsha Bhogle (supra) the Tribunal went into the objects and intention of Section 80RR
grounds No. 2. Ground No.3 pertains to
deduction under section 80RR which was not allowed by the
A.O. and learned ... appeal is with
reference to claim of deduction under section 80RR amounting
to Rs.40,00,197/- being 75% of foreign receipts
order of
the learned Commissioner (Appeals) in disallowing the deduction under
section 80RR of the Income Tax Act, 1961 (for short ... Form 10H. Therefore, the Assessing Officer denied the claim
under section 80RR , inter-alia, in respect of above two amounts. Being
aggrieved, the assessee filed
erred in upholding disallowance of appellant's claim under Section 80RR of the IT Act, 1961, without appreciating that--
(a) the appellant ... which in fact is not a disqualification under the provisions of Section 80RR ;
(ii) this activity did not contribute to a greater understanding of India
appeal and has raised the issue relating to deduction claimed under Section 80RR on the share income derived by him from the firm ... falls within the classification of 'artist' as defined in Section 80RR . He pleaded that Section 80RR makes reference to the individual