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2018 (9) TMI 1165 - ITAT CHANDIGARHDeduction u/s 80IC - deduction @ 100% of profit derived from manufacturing activities of unit - Held that:- We do not agree to the above contention raised by the Revenue at this stage. A perusal of the order of the Assessing officer reveals that the Assessing officer has not disputed that the assessee unit has carried out substantial expansion as provided under clause (b) of sub section (2) read with clause (ix) of sub section (7) of section 80IC of the Act. Almost similar view has also been taken in the case of ‘M/s Stovekraft India vs. Commissioner of Income Tax’ [2017 (12) TMI 69 - HIMACHAL PRADESH HIGH COURT] as held Revenue has not disputed, (a) the units having carried out substantial expansion within the definition of the Section, (b) their entitlement and extent of deduction would be dependent upon interpretation of the relevant provisions. Eligibility for deduction u/s 80IC in respect of interest income - Held that:- We restore the issue relating ground No.2 to the limited extent that if the interest expenditure incurred by the assessee has nexus with the interest income earned by the assessee, the assessee will be eligible for netting off/setting off of the same against the interest income. The matter is, therefore, restored to the file of the Assessing Officer to decide this issue afresh on this limited point. - Appeal of the assessee is treated as allowed for statistical purposes.
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