Mere commercial connection between income and industrial undertaking would not be sufficient for claiming deduction under section 80-IB

Mere commercial connection between income and industrial undertaking would not be sufficient for claiming deduction under section 80-IB.

The derivation of the income must be directly connected with the business in the sense that the income is generated by the business. It would not be sufficient if it is generated by the exploitation of a business asset.

The fact that the Legislature has used the expression "profits and gains derived from the business of industrial undertaking" has some significance and it connotes that the immediate and effective source of income eligible for grant of relief under section 80-IB must be the industrial undertaking itself and not any other source. - [2010] 8 TAXMANN.COM 267 (AHD. - ITAT)