section 80A(6) provides that notwithstanding anything
to the contrary contained in section 10A or section 10AA or section 10B
or section 10BA ... section 80A(6) of
the Act. As we have stated above, the provisions of section 80A(6) will
override the provisions of section 80IA(8
justified in confirming disallowance of deduction under section
80IB /IC by applying provisions of section 80IA(8) read with 80IB(13)
and 80IC ... purposes of computing deduction under section 80IB /IC read with
section 80IA(8) of The Act.
(iii) That Ld. CIT(A) has failed to appreciate
view of the provisions of Sec. 10A(7) r.w. sub-section
(8) and (10) of Sec. 80IA of 'Act'. Per contra ... Umbergaum
Industries, as a result whereof the provisions of Sec. 80IA(7) and
80IA(8) were held to be not applicable, the factual position
services. In terms of
Clause (i) of Explanation to Sub-section (8) of Section 80IA of the Act, the market value in
relation to goods ... value of the said supplies
for the purposes of Sub-section (8) of Section 80IA of the Act."
15. He submitted, in case
purposes of computing
deduction under section 80IB /IC read with section 80IA(8) of
the Act.
(iii) That the assessing officer has failed to appreciate ... following
deduction u/s 80IB /IC AO :
observations:
by applying provisions Page 12 Para 13.6
of sec.80IA(8) in 32,49,27,532 Page
Wipro Limited, Bangalore vs Assistant Commissioner Of Income Tax, ... on 14 June, 2023
IN THE
play between
Section 92 and Sections 80IA /IB of the Act. It was observed by him
that, as per the provisions of Section 92CA ... benchmarked having regard to the provisions of section 92 and
Section 80IB r.w.s 80IA(8
computation of deduction
under section 80-IA of the Act, whereas as per explanation to section
80IA(8) of the Act, "market value ... required to be taken. He in this respect has relied upon section
80IA(8) of the Income Tax Act r.w.s. 92BA
computation of deduction
under section 80-IA of the Act, whereas as per explanation to section
80IA(8) of the Act. "'market value ... required to be taken. He in this respect has relied upon section 80IA(8) of
the Income Tax Act r.w.s. 92BA
computation of deduction
under section 80-IA of the Act, whereas as per explanation to section
80IA(8) of the Act, "market value ... required to be taken. He in this respect has relied upon section
80IA(8) of the Income Tax Act r.w.s. 92BA
