Derived from, the words 'derived from' in s. 80HH of the Income-tax Act, 1961 must be understood as something which has direct or immediate nexus with the appellant's industrial undertaking. Although electricity may be required for the purposes of the industrial undertaking, the deposit required for its supply is a step removed from the business of the industrial undertaking. The derivation of profits on the deposit made with the Electricity Board cannot be said to flow directly from the industrial undertaking itself. (AIR 1955 SC 74 foll), Pandian Chemicals v. Commissioner of Income Tax, (2003) 5 SCC 590 (592). (Income-tax Act, 1961, s. 80HH)
Derived from, a direct nexus between the profits and gains and the industrial undertaking, Belapur Sugar & Allied Industries Ltd. v. C.C.E., (1999) 4 SCC 98.