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2011 (8) TMI 307 - MADRAS HIGH COURTDeduction u/s 80I - Apportionment of expenses - The assessee is a Public Limited Company engaged in the manufacture of pharmaceuticals and packaged fast foods - The assessee has three manufacturing units in Madras, Hyderabad and Bangalore - In the statement of income filed, the assessee claimed deduction of a sum of Rs.19,33,104/- under Section 80-I of the Income Tax Act, 1961 relatable to the Hyderabad Unit - Held that:- merger had taken place as early as in the year 1988 - It is not as though the Hyderabad Unit s Profit and Loss Account have not come for consideration before the assessee company in the matter of allocation of the expenditure - On the admitted fact that the income and expenditure of the three Units are considered at the Corporate Office, with the apportionment thus fixed at 38.77% on the basis of the total turnover to the turnover relatable to the Hyderabad Unit, the expenditure apportioned, thus was rightly made by the Assessing Officer, as confirmed by the Commissioner of Income Tax (Appeals) - Therefore, set aside the order of the Tribunal in remanding the case to the Assessing Officer for re-working of the apportionment.
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