Section 36(1)(viii) Deduction Requires Deployment of ‘Own Funds’; General Business Income Not Automatically Eligible Under ‘Derived From’ Test: Supreme Court

The Supreme Court has dismissed a batch of appeals filed by the National Cooperative Development Corporation (NCDC), ruling that the statutory deduction under Section 36(1)(viii) of the Income Tax Act, 1961, is strictly limited to profits “derived from” the specific business of providing long-term finance. The Court held that ancillary income such as dividends from

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