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2016 (9) TMI 1301 - AT - Income TaxDeduction u/s 80IC in relation to the profits earned in Haridwar Unit - Held that:- AO and the DRP have merely noted the difference in the figures without appreciating reconciliation and the unit-wise computation of net income made by the assessee, which is in conformity with the methodology accepted in the past in the income-tax returns filed by the assessee. On this aspect, in our view, there is an apparent mistake made by the Assessing Officer in computing the amount of deduction allowable to the assessee under section 80IC of the Act. Pertinently, the basis of allocation of administrative, sales and interest expenses, etc. adopted by the assessee to arrive at the eligible deduction under section 80IC is similar to that adopted for computing the deduction under section 80IB of the Act. Whereas, the Assessing Officer accepts the working of deduction under section 80IB of the Act as determined by the assessee, while on the other hand, determination of deduction under section 80IC of the Act has been tinkered with. This reflects inherent inconsistency on the part of the Assessing Officer on the issue of allocation of transactions of Head office and on account of administrative, sales and interest expenditure, etc. to the other manufacturing units, including those eligible for deduction under section 80 IB and 80 IC of the Act. For the said reasons, we deem it fit and proper to set-aside the matter back to the file of Assessing Officer, who shall revisit the computation of deduction allowable to the assessee under section 80IC of the Act afresh.
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