My client has set up a unit in GIFT City. What exactly is the section 80LA deduction, how long does it last, and what has to go with the return?
Section 80LA(1A) allows a Unit of an International Financial Services Centre a deduction of one hundred per cent of the income referred to in section 80LA(2), for any ten consecutive assessment years, at the option of the assessee, out of fifteen years beginning with the assessment year relevant to the previous year in which the permission or registration was obtained. The permission or registration counted for that starting point is one under clause (a) of section 23(1) of the Banking Regulation Act 1949, or under the Securities and Exchange Board of India Act 1992, or under the International Financial Services Centres Authority Act 2019.
Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Income-tax Act 1961, s.80LA(1), (1A), (2), (3) and the Explanation, as printed on the Income-tax Department's section page carrying the year stamp 2025; Income-tax Rules 1962, rule 19AE. It bears on section 80LA, section 80LA(1), section 80LA(1A), section 80LA(2), section 80LA(3), section 80AC, section 288, section 10(4F), section Rule 19AE of the Income Tax Act 1961, in Deductions & Disallowances and How Tax Law Is Read matters.
Three points decide most files. First, the fifteen-year window starts running from the year the permission or registration was obtained, whether or not the unit is profitable, so a unit that takes four years to reach profit has already burned four of its fifteen; the ten years the assessee chooses must be CONSECUTIVE, so the option is really a choice of starting year, not a right to cherry-pick profitable years. Second, section 80LA(1A) is a different provision from section 80LA(1), which deals with an Offshore Banking Unit in a Special Economic Zone on a five-plus-five basis — one hundred per cent for five consecutive assessment years and then fifty per cent for five more, with a proviso raising the second five to one hundred per cent for assessment years commencing on or after 1 April 2023. Reading the wrong sub-section produces the wrong number of years and the wrong rate. Third, section 80LA(3) is expressed as a condition of allowance: no deduction is allowed unless the assessee furnishes ALONG WITH THE RETURN both an accountant's report certifying the deduction has been correctly claimed and a copy of the permission or registration, and rule 19AE prescribes that report in Form No. 10CCF. But the courts have begun to read that requirement as directory rather than mandatory. In Volark Leasing IFSC Pvt. Ltd. v. ACIT (ITAT Ahmedabad "C" Bench, I.T.A. No. 357/Ahd/2025, AY 2023-24, order dated 29 October 2025) the Tribunal held that denial of the section 80LA deduction "merely on account of delayed filing of the prescribed Form 10CCF which otherwise was filed before the intimation was made on the assessee by CPC under Section 143(1) of the Act was not as per law", and directed the Assessing Officer to grant the deduction; it applied the line of authority on section 80-IA(7) and similar audit-report requirements, including CIT v. Contimeters Electricals (P.) Ltd. (Delhi HC), CIT v. G.M. Knitting Industries (SC) and Bajaj Tempo Ltd. v. CIT (SC). The same point is before the Delhi High Court in MUFG Bank Ltd. v. ACIT (W.P.(C) 2570/2026), where a demand of about Rs.322 crores raised under section 143(1)(a) on the footing that Form 10CCF was not filed by the day the return was filed has been stayed as to recovery by an interim order dated 10 March 2026, the matter being listed for 12 May 2026. File the form with the return; but a late form is not necessarily fatal, and a demand raised on that ground alone is worth contesting. Note also the income side: section 80LA(2)(c) reaches the income of a Unit of the IFSC 'from its business for which it has been approved for setting up in such a Centre in a Special Economic Zone', so income from an activity outside the approved business is outside the deduction; and section 80LA(2)(d) adds income arising from the transfer of an aircraft or a ship which was leased by such a unit, subject to the unit having commenced operation on or before 31 March 2030.
Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.
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Not a case. Section 80LA(1) applies where the gross total income of an assessee, being a scheduled bank or any bank incorporated by or under the laws of a country outside India and having an Offshore Banking Unit in a Special Economic Zone, includes any income referred to in sub-section (2): the deduction is (a) one hundred per cent of such income for five consecutive assessment years beginning with the assessment year relevant to the previous year in which the permission under clause (a) of section 23(1) of the Banking Regulation Act 1949 or permission or registration under the Securities and Exchange Board of India Act 1992 or any other relevant law was obtained, and thereafter (b) fifty per cent of such income for five consecutive assessment years, with a proviso that for the assessment year commencing on or after 1 April 2023 the deduction under clause (b) shall be one hundred per cent. Section 80LA(2) identifies the income for both sub-section (1) and sub-section (1A) as income (a) from an Offshore Banking Unit in a Special Economic Zone; or (b) from the business referred to in section 6(1) of the Banking Regulation Act 1949 with an undertaking located in a Special Economic Zone or any other undertaking which develops, develops and operates, or develops, operates and maintains a Special Economic Zone; or (c) from any Unit of the International Financial Services Centre from its business for which it has been approved for setting up in such a Centre in a Special Economic Zone; (d) arising from the transfer of an asset, being an aircraft or a ship, which was leased by a unit referred to in clause (c) to a person, subject to the condition that the unit has commenced operation on or before 31 March 2030, with an Explanation giving 'aircraft' and 'ship' the meaning assigned in the Explanation to clause (4F) of section 10. The Explanation to the section defines 'International Financial Services Centre' by reference to clause (q) of section 2 of the Special Economic Zones Act 2005, 'scheduled bank' by reference to clause (e) of section 2 of the Reserve Bank of India Act 1934, 'Special Economic Zone' by reference to clause (za) of section 2 of the Special Economic Zones Act 2005, and 'Unit' by reference to clause (zc) of section 2 of that Act.
Section 80LA(1A) provides that where the gross total income of an assessee, being a Unit of an International Financial Services Centre, includes any income referred to in sub-section (2), there shall be allowed, in accordance with and subject to the provisions of the section, a deduction from such income of an amount equal to one hundred per cent of such income for any ten consecutive assessment years, at the option of the assessee, out of fifteen years, beginning with the assessment year relevant to the previous year in which the permission under clause (a) of section 23(1) of the Banking Regulation Act 1949, or permission or registration under the Securities and Exchange Board of India Act 1992, or permission or registration under the International Financial Services Centres Authority Act 2019 (50 of 2019), was obtained. Section 80LA(3) provides that no deduction under the section shall be allowed unless the assessee furnishes along with the return of income (i) the report of an accountant as defined in the Explanation below section 288(2), in the form specified by the Central Board of Direct Taxes under clause (i) of sub-section (2) of section 80LA as it stood immediately before its substitution by the present section, certifying that the deduction has been correctly claimed in accordance with the provisions of the section, and (ii) a copy of the permission obtained under clause (a) of section 23(1) of the Banking Regulation Act 1949 or a copy of the permission or registration obtained under the International Financial Services Centres Authority Act 2019. Rule 19AE provides that the report of the accountant required to be furnished by the assessee under section 80LA(3) shall be in Form No. 10CCF.
Not a judicial route. The section is written as two parallel reliefs sharing one definition of qualifying income. Sub-section (1) is the older Offshore Banking Unit relief, tapered at five years and then restored to the full rate for assessment years from 1 April 2023; sub-section (1A) is the IFSC unit relief, and its structure — ten consecutive years chosen out of a fifteen-year outer window that starts with the year of permission — is the standard Indian technique for a start-up incentive that must not reward indefinite deferral: the outer window forces the unit to become profitable within a fixed period, while the option and the consecutiveness requirement together let the unit pick its starting point without letting it skip loss years. The registration triggers listed in sub-section (1A) track the three regulators that can license activity in the Centre, and the addition of the International Financial Services Centres Authority Act 2019 to that list reflects the transfer of regulatory authority over the Centre to the Authority. Sub-section (3) makes the certificate and the permission conditions of allowance rather than matters of proof, which is what allows the claim to be denied on the papers.
Where the gross total income of an assessee, being a Unit of an International Financial Services Centre, includes any income referred to in sub-section (2), there shall be allowed, in accordance with and subject to the provisions of this section, a deduction from such income, of an amount equal to one hundred per cent of such income for any ten consecutive assessment years, at the option of the assessee, out of fifteen years, beginning with the assessment year relevant to the previous year in which the permission, under clause (a) of sub-section (1) of section 23 of the Banking Regulation Act, 1949 (10 of 1949) or permission or registration under the Securities and Exchange Board of India Act, 1992 (15 of 1992) or permission or registration under the International Financial Services Centres Authority Act, 2019 (50 of 2019) was obtained.
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Handle my notice → Ask a CA on WhatsAppSection 80LA(1A) allows a Unit of an International Financial Services Centre a deduction of one hundred per cent of the income referred to in section 80LA(2), for any ten consecutive assessment years, at the option of the assessee, out of fifteen years beginning with the assessment year relevant to the previous year in which the permission or registration was obtained. The permission or registration counted for that starting point is one under clause (a) of section 23(1) of the Banking Regulation Act 1949, or under the Securities and Exchange Board of India Act 1992, or under the International Financial Services Centres Authority Act 2019. This was decided by the CBDT Circulars & Instructions (Not applicable — statutory text) and bears on section 80LA, section 80LA(1), section 80LA(1A), section 80LA(2), section 80LA(3), section 80AC, section 288, section 10(4F), section Rule 19AE of the Income Tax Act 1961. It is reported as Income-tax Act 1961, s.80LA(1), (1A), (2), (3) and the Explanation, as printed on the Income-tax Department's section page carrying the year stamp 2025; Income-tax Rules 1962, rule 19AE. Three points decide most files. First, the fifteen-year window starts running from the year the permission or registration was obtained, whether or not the unit is profitable, so a unit that takes four years to reach profit has already burned four of its fifteen; the ten years the assessee chooses must be CONSECUTIVE, so the option is really a choice of starting year, not a right to cherry-pick profitable years. Second, section 80LA(1A) is a different provision from section 80LA(1), which deals with an Offshore Banking Unit in a Special Economic Zone on a five-plus-five basis — one hundred per cent for five consecutive assessment years and then fifty per cent for five more, with a proviso raising the second five to one hundred per cent for assessment years commencing on or after 1 April 2023. Reading the wrong sub-section produces the wrong number of years and the wrong rate. Third, section 80LA(3) is expressed as a condition of allowance: no deduction is allowed unless the assessee furnishes ALONG WITH THE RETURN both an accountant's report certifying the deduction has been correctly claimed and a copy of the permission or registration, and rule 19AE prescribes that report in Form No. 10CCF. But the courts have begun to read that requirement as directory rather than mandatory. In Volark Leasing IFSC Pvt. Ltd. v. ACIT (ITAT Ahmedabad "C" Bench, I.T.A. No. 357/Ahd/2025, AY 2023-24, order dated 29 October 2025) the Tribunal held that denial of the section 80LA deduction "merely on account of delayed filing of the prescribed Form 10CCF which otherwise was filed before the intimation was made on the assessee by CPC under Section 143(1) of the Act was not as per law", and directed the Assessing Officer to grant the deduction; it applied the line of authority on section 80-IA(7) and similar audit-report requirements, including CIT v. Contimeters Electricals (P.) Ltd. (Delhi HC), CIT v. G.M. Knitting Industries (SC) and Bajaj Tempo Ltd. v. CIT (SC). The same point is before the Delhi High Court in MUFG Bank Ltd. v. ACIT (W.P.(C) 2570/2026), where a demand of about Rs.322 crores raised under section 143(1)(a) on the footing that Form 10CCF was not filed by the day the return was filed has been stayed as to recovery by an interim order dated 10 March 2026, the matter being listed for 12 May 2026. File the form with the return; but a late form is not necessarily fatal, and a demand raised on that ground alone is worth contesting. Note also the income side: section 80LA(2)(c) reaches the income of a Unit of the IFSC 'from its business for which it has been approved for setting up in such a Centre in a Special Economic Zone', so income from an activity outside the approved business is outside the deduction; and section 80LA(2)(d) adds income arising from the transfer of an aircraft or a ship which was leased by such a unit, subject to the unit having commenced operation on or before 31 March 2030. If it applies to you, the first step is this: Fix the start of the fifteen-year window by the assessment year relevant to the previous year in which the permission or registration was OBTAINED, and put that date on the file with the permission letter itself.
Not a case. Section 80LA(1) applies where the gross total income of an assessee, being a scheduled bank or any bank incorporated by or under the laws of a country outside India and having an Offshore Banking Unit in a Special Economic Zone, includes any income referred to in sub-section (2): the deduction is (a) one hundred per cent of such income for five consecutive assessment years beginning with the assessment year relevant to the previous year in which the permission under clause (a) of section 23(1) of the Banking Regulation Act 1949 or permission or registration under the Securities and Exchange Board of India Act 1992 or any other relevant law was obtained, and thereafter (b) fifty per cent of such income for five consecutive assessment years, with a proviso that for the assessment year commencing on or after 1 April 2023 the deduction under clause (b) shall be one hundred per cent. Section 80LA(2) identifies the income for both sub-section (1) and sub-section (1A) as income (a) from an Offshore Banking Unit in a Special Economic Zone; or (b) from the business referred to in section 6(1) of the Banking Regulation Act 1949 with an undertaking located in a Special Economic Zone or any other undertaking which develops, develops and operates, or develops, operates and maintains a Special Economic Zone; or (c) from any Unit of the International Financial Services Centre from its business for which it has been approved for setting up in such a Centre in a Special Economic Zone; (d) arising from the transfer of an asset, being an aircraft or a ship, which was leased by a unit referred to in clause (c) to a person, subject to the condition that the unit has commenced operation on or before 31 March 2030, with an Explanation giving 'aircraft' and 'ship' the meaning assigned in the Explanation to clause (4F) of section 10. The Explanation to the section defines 'International Financial Services Centre' by reference to clause (q) of section 2 of the Special Economic Zones Act 2005, 'scheduled bank' by reference to clause (e) of section 2 of the Reserve Bank of India Act 1934, 'Special Economic Zone' by reference to clause (za) of section 2 of the Special Economic Zones Act 2005, and 'Unit' by reference to clause (zc) of section 2 of that Act. The matter was decided on 2025-04-01 by the CBDT Circulars & Instructions (Not applicable — statutory text). On those facts the CBDT Circulars & Instructions held as follows. Section 80LA(1A) provides that where the gross total income of an assessee, being a Unit of an International Financial Services Centre, includes any income referred to in sub-section (2), there shall be allowed, in accordance with and subject to the provisions of the section, a deduction from such income of an amount equal to one hundred per cent of such income for any ten consecutive assessment years, at the option of the assessee, out of fifteen years, beginning with the assessment year relevant to the previous year in which the permission under clause (a) of section 23(1) of the Banking Regulation Act 1949, or permission or registration under the Securities and Exchange Board of India Act 1992, or permission or registration under the International Financial Services Centres Authority Act 2019 (50 of 2019), was obtained. Section 80LA(3) provides that no deduction under the section shall be allowed unless the assessee furnishes along with the return of income (i) the report of an accountant as defined in the Explanation below section 288(2), in the form specified by the Central Board of Direct Taxes under clause (i) of sub-section (2) of section 80LA as it stood immediately before its substitution by the present section, certifying that the deduction has been correctly claimed in accordance with the provisions of the section, and (ii) a copy of the permission obtained under clause (a) of section 23(1) of the Banking Regulation Act 1949 or a copy of the permission or registration obtained under the International Financial Services Centres Authority Act 2019. Rule 19AE provides that the report of the accountant required to be furnished by the assessee under section 80LA(3) shall be in Form No. 10CCF.
Not a judicial route. The section is written as two parallel reliefs sharing one definition of qualifying income. Sub-section (1) is the older Offshore Banking Unit relief, tapered at five years and then restored to the full rate for assessment years from 1 April 2023; sub-section (1A) is the IFSC unit relief, and its structure — ten consecutive years chosen out of a fifteen-year outer window that starts with the year of permission — is the standard Indian technique for a start-up incentive that must not reward indefinite deferral: the outer window forces the unit to become profitable within a fixed period, while the option and the consecutiveness requirement together let the unit pick its starting point without letting it skip loss years. The registration triggers listed in sub-section (1A) track the three regulators that can license activity in the Centre, and the addition of the International Financial Services Centres Authority Act 2019 to that list reflects the transfer of regulatory authority over the Centre to the Authority. Sub-section (3) makes the certificate and the permission conditions of allowance rather than matters of proof, which is what allows the claim to be denied on the papers. In the words reproduced by the source cited on this page: "Where the gross total income of an assessee, being a Unit of an International Financial Services Centre, includes any income referred to in sub-section (2), there shall be allowed, in accordance with and subject to the provisions of this section, a deduction from such income, of an amount equal to one hundred per cent of such income for any ten consecutive assessment years, at the option of the assessee, out of fifteen years, beginning with the assessment year relevant to the previous year in which the permission, under clause (a) of sub-section (1) of section 23 of the Banking Regulation Act, 1949 (10 of 1949) or permission or registration under the Securities and Exchange Board of India Act, 1992 (15 of 1992) or permission or registration under the International Financial Services Centres Authority Act, 2019 (50 of 2019) was obtained."
It was decided by the CBDT Circulars & Instructions on 2025-04-01 and is reported as Income-tax Act 1961, s.80LA(1), (1A), (2), (3) and the Explanation, as printed on the Income-tax Department's section page carrying the year stamp 2025; Income-tax Rules 1962, rule 19AE. Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them. A CBDT circular or instruction binds officers of the department but not the assessee and not the courts. Where a circular helps you, you may hold the department to it. Where it hurts you, it cannot override the Act or a judgment. On section 80LA, section 80LA(1), section 80LA(1A), section 80LA(2), section 80LA(3), section 80AC, section 288, section 10(4F), section Rule 19AE, the practical question is whether the facts of your own notice match the facts of this case closely enough for the same rule to apply.
It cuts both ways and is cited by both sides. Section 80LA(1A) provides that where the gross total income of an assessee, being a Unit of an International Financial Services Centre, includes any income referred to in sub-section (2), there shall be allowed, in accordance with and subject to the provisions of the section, a deduction from such income of an amount equal to one hundred per cent of such income for any ten consecutive assessment years, at the option of the assessee, out of fifteen years, beginning with the assessment year relevant to the previous year in which the permission under clause (a) of section 23(1) of the Banking Regulation Act 1949, or permission or registration under the Securities and Exchange Board of India Act 1992, or permission or registration under the International Financial Services Centres Authority Act 2019 (50 of 2019), was obtained. Section 80LA(3) provides that no deduction under the section shall be allowed unless the assessee furnishes along with the return of income (i) the report of an accountant as defined in the Explanation below section 288(2), in the form specified by the Central Board of Direct Taxes under clause (i) of sub-section (2) of section 80LA as it stood immediately before its substitution by the present section, certifying that the deduction has been correctly claimed in accordance with the provisions of the section, and (ii) a copy of the permission obtained under clause (a) of section 23(1) of the Banking Regulation Act 1949 or a copy of the permission or registration obtained under the International Financial Services Centres Authority Act 2019. Rule 19AE provides that the report of the accountant required to be furnished by the assessee under section 80LA(3) shall be in Form No. 10CCF. It arises in Deductions & Disallowances and How Tax Law Is Read matters, on section 80LA, section 80LA(1), section 80LA(1A), section 80LA(2), section 80LA(3), section 80AC, section 288, section 10(4F), section Rule 19AE of the Income Tax Act 1961, and was decided by Not applicable — statutory text. Before relying on it, read the source linked on this page and check whether it has since been distinguished, overruled or overtaken by an amendment to the Income Tax Act. In practice the steps that follow from it are these. Choose the ten consecutive assessment years deliberately and record the choice; because they must be consecutive, the only real decision is which year to start in, and starting too early wastes the relief on loss or low-profit years. Use section 80LA(1A) for a Unit of an IFSC and section 80LA(1) for an Offshore Banking Unit in a Special Economic Zone — they carry different rates and different periods, and the proviso raising the second five years to one hundred per cent belongs to clause (b) of sub-section (1), not to sub-section (1A). Obtain the accountant's report in Form No. 10CCF, prescribed by rule 19AE, from an accountant as defined in the Explanation below section 288(2), and file it ALONG WITH the return together with a copy of the permission or registration — section 80LA(3) makes both a condition of allowance on its face. If the form was filed late, do not concede the deduction: rely on Volark Leasing IFSC Pvt. Ltd. v. ACIT (ITAT Ahmedabad, 29 October 2025), which held the requirement directory where the form was filed before the section 143(1) intimation, and note that the point is pending before the Delhi High Court in MUFG Bank Ltd. v. ACIT. Map the unit's income streams against section 80LA(2) before claiming: for an IFSC unit the gateway is clause (c), which is limited to the business for which the unit was approved for setting up in the Centre. Where the claim includes gain on the transfer of a leased aircraft or ship under section 80LA(2)(d), check that the unit commenced operation on or before 31 March 2030 and note that 'aircraft' and 'ship' take their meaning from the Explanation to section 10(4F). File the return by the due date under section 139(1) — section 80AC bars the deduction outright on a late return; see the companion entry on section 80AC and section 115JC.
Still good law. Sub-section (1A) and the whole of sub-section (2) were read a second time on the Department's archived page carrying the year stamp 2024 (No. 1) and came back in identical words save that clause (2)(d) there carries the date 31 March 2025 in place of 31 March 2030 — which corroborates both the text of sub-section (1A) and the fact and direction of the 2025 amendment recorded in the Department's footnote 99. The page relied on for the current text carries the year stamp 2025, the highest located; pages -21 and -23 carry the stamps 2024 (No. 2) and 2018. No judicial decision construing section 80LA(1A) itself — the ten-out-of-fifteen-year computation — was located. There is, however, authority on section 80LA(3) and Form 10CCF, which an earlier pass missed: Volark Leasing IFSC Pvt. Ltd. v. ACIT/DCIT, Circle, Gandhinagar, ITAT Ahmedabad "C" Bench, I.T.A. No. 357/Ahd/2025, AY 2023-24, order dated 29 October 2025 (indiankanoon.org/doc/67261817), which allowed the deduction notwithstanding late filing of the form; and MUFG Bank Ltd. v. ACIT, Delhi High Court, W.P.(C) 2570/2026, orders of 24 February 2026 and 10 March 2026 (indiankanoon.org/doc/114640655 and /doc/143799010), an interim stay of recovery on the same point. The productive search term is the FORM NUMBER, "10CCF"; searches on the section number return only orders quoting the section 80AC list. Sub-section (1A) was separately confirmed word-for-word against the indiankanoon bare-Act text of section 80LA (doc 29520403), and the substitution of "2030" for "2025" in sub-section (2)(d) was confirmed against clause 19 of the Finance Bill 2025. I did not check for any writ challenge to the provision. No source could be cited for that finding. Checking whether an authority still stands matters as much as knowing what it held: a decision may be overruled on one point and survive on another, or the provision it interprets may have been amended since. Read the source and the editor's note on this page before relying on it in a reply to an Assessing Officer or in an appeal.
This is a statutory entry, not a decision. 'decided_on' is 1 April 2025, which is the commencement date the Department's own footnote 99 on the section page gives for the current form of the date in section 80LA(2)(d) — 'Sub. for "2025" by Act No. 7 of 2025, w.e.f. 1-4-2025. Earlier "2025" was Sub. for "2024" by Act No. 8 of 2024, w.e.f. 1-4-2024' — and not a decision date. Footnote 98 on the same page reads 'Ins. by Act No. 08 of 2023, w.e.f. 1-4-2023'. The Department prints Act numbers only, not popular names, and I have not gone behind them. The dates on which sub-section (1A) and the reference to the International Financial Services Centres Authority Act 2019 were first inserted were NOT established this pass and are therefore not stated. One oddity in the text as printed deserves recording: section 80LA(3)(i) prescribes the report by reference to 'the form specified by the Central Board of Direct Taxes under clause (i) of sub-section (2) of section 80LA, as it stood immediately before its substitution by this section' — that is, by reference to a repealed sub-section — and rule 19AE independently states that the report under section 80LA(3) shall be in Form No. 10CCF. I read rule 19AE this pass; I did not read Form 10CCF itself. The Department's pages at /w/section-80la (year stamp 2009), -2 (2011), -6 (2013), -8 (2006), -10 (2008), -12 (2015), -16 (2019 No. 2), -18 (2022), -20 (2024 No. 1), -21 (2024 No. 2) and -23 (2018) are all archived and must not be used to state the current position; the live page located is -22, year stamp 2025. The tier value 'cbdt' is used because the library's fixed tier vocabulary has no value for a statutory entry. This library shows the verification state of every entry openly. This entry has not yet been read in full by a chartered accountant. The summary reflects the sources listed on this page. Read the source before you rely on it in a reply to an Assessing Officer or in an appeal before the Commissioner (Appeals) or the Income Tax Appellate Tribunal.
Section 80LA(1A) provides that where the gross total income of an assessee, being a Unit of an International Financial Services Centre, includes any income referred to in sub-section (2), there shall be allowed, in accordance with and subject to the provisions of the section, a deduction from such income of an amount equal to one hundred per cent of such income for any ten consecutive assessment years, at the option of the assessee, out of fifteen years, beginning with the assessment year relevant to the previous year in which the permission under clause (a) of section 23(1) of the Banking Regulation Act 1949, or permission or registration under the Securities and Exchange Board of India Act 1992, or permission or registration under the International Financial Services Centres Authority Act 2019 (50 of 2019), was obtained. Section 80LA(3) provides that no deduction under the section shall be allowed unless the assessee furnishes along with the return of income (i) the report of an accountant as defined in the Explanation below section 288(2), in the form specified by the Central Board of Direct Taxes under clause (i) of sub-section (2) of section 80LA as it stood immediately before its substitution by the present section, certifying that the deduction has been correctly claimed in accordance with the provisions of the section, and (ii) a copy of the permission obtained under clause (a) of section 23(1) of the Banking Regulation Act 1949 or a copy of the permission or registration obtained under the International Financial Services Centres Authority Act 2019. Rule 19AE provides that the report of the accountant required to be furnished by the assessee under section 80LA(3) shall be in Form No. 10CCF.
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My society filed its return only in response to a 148 notice. Can it still claim 80P?
CPC denied my society's 80P in a 143(1) intimation because the return was late. Can it?
Our co-operative credit society filed its return late and lost the section 80P deduction under section 80AC. The Chief Commissioner has rejected our section 119(2)(b) condonation application for want of sufficient cause. Is that rejection sustainable?
My co-operative society filed its return late and lost section 80P because of section 80AC. If the delay is condoned under section 119(2)(b), does the deduction come back?