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TMI Blog2019 (5) TMI 198X X X X Extracts X X X X X X X X Extracts X X X X ..... me is to save the expenditure and enduring benefits test cannot be applied. It was held that the expenditure must he allowed in the year in which it was incurred. Similarly, in the case of Commissioner of Income Tax Vs. Simpson And Co. Ltd. (No.1) [ 1996 (6) TMI 12 - MADRAS HIGH COURT] held that the amount paid to the employee under voluntary retirement scheme is an allowable deduction since t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion of the Revenue. The second head of the interest income was interest received from the customers on delayed payments. Correctly therefore, the Tribunal held that such interest was also part of the Assessee s export business. There is a reference to the income from Hundies. However, there is no clarity on this nature of income. The Assessing Officer has not discussed any facts relatable to t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (ii) Whether on the facts and in circumstances of the case and in law, the ITAT was correct in holding that interest income earned from the customers and Hundies, interest of MSEB and MIDC were the part of total eligible profits for the purpose of computing deduction u/s. 80HHC of the Income Tax Act, 1961 ? 3. The Respondent Assessee is a Private Limited Company. The Appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... retirement scheme is an allowable deduction since the expenditure was incurred on the ground of commercial expediencies. 5. Question No.(ii) relates to the computation of Assessee s income for deduction under Section 80 HHC of the Income Tax Act, 1961. The Revenue contends that by applying explanation (baa), 90% thereof will be deducted from the Assessee s business income. The Tribunal h ..... X X X X Extracts X X X X X X X X Extracts X X X X
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