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Challenge to disallowance of deduction under section 80-I for difference of interest received and paid. Analysis: The appellant challenged the disallowance of deduction under section 80-I for a specific amount, arguing that it should be eligible for deduction. The appellant's counsel contended that there was a misapplication of law leading to an incorrect conclusion. The appellant tried to distinguish previous judgments cited by the department, emphasizing that the present case involved inter-corporate units, not a bank. The department, however, relied on various decisions to support its stance, asserting that the appellant's argument lacked a direct nexus and that netting was impermissible. The tribunal considered these arguments. The appellant declared total income, including long-term capital gains, and claimed deduction under section 80-I on interest received from sister concerns. The assessing officer disallowed this deduction, citing the necessity of a connection between the priority industry and interest receipts. The tribunal analyzed section 80-I, emphasizing that income must be directly generated from the business. It concluded that the interest earned could not be considered directly derived from the industrial undertaking, thus disallowing the deduction under section 80-I. Moreover, the appellant raised concerns about the order's clarity and cited judicial precedents to support their claim of perversity. However, the tribunal found the order to be appropriate and not perverse. Various decisions and the case facts were analyzed to determine that the interest earned was not related to the business activity, leading to the dismissal of the appeal. The tribunal's decision was in line with previous judgments and the specific requirements outlined in the law. In conclusion, the tribunal dismissed the appeal, ruling that the interest income earned by the appellant was not directly derived from the business or industrial undertaking, making it ineligible for the deduction under section 80-I. The decision was based on a thorough analysis of relevant legal provisions and judicial precedents, ensuring alignment with the statutory requirements.
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