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2012 (8) TMI 358 - ITAT, AHMEDABADDisallowance of claim u/s 80 IB - CIT(A) deleted the addition - Held that:- The AO’s action of allocating the profit in the ratio of sales turnover is not accepted as the two units i.e. Unit- III and Unit –IV are separately registered with Excise Authorities, the books of accounts are separately maintained, two units are producing different items and Unit-IV is producing items in which the appellant has got monopoly, accordingly, it will be unfair to compute profits of Unit-IV in the same proportion as that of overall business for the purpose of section 80IB - the appellant has suomoto apportioned administrative expenses to Unit-IV and accordingly, further apportionment and disallowance of deduction u/s. 80IB is not required - sustain the apportionment worked out by the assessee - against revenue.
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