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2015 (12) TMI 514 - AT - Income TaxDisallowance u/s 14A - Held that:- DRP directed the Assessing Officer to exclude bank charges and other financial charges while determining the figure of the interest expenditure for quantifying the disallowance under Rule 8D of the Rules. The Revenue has challenged the aforesaid direction of the DRP. After considering the rival stands, we find no infirmity in the decision of the DRP, which is in conformity with the phraseology of Rule 8D(2)(ii) of the Rules. - Decided against revenue Denial of claim of deduction under section 80-IC in respect of the two units at Guwahati manufacturing mosquito repellent mats and liquid - Held that:- The relevant discussion in the order of DRP reveals that apart from the difference in the products being manufactured, it has also been brought out that the manufacturing process involved in manufacture of mosquito repellent coils is different than the process required for manufacturing mosquito repellent mat and liquid. These factual aspects have not been negated by the Revenue and, therefore, the decision of the DRP cannot be faulted with. Apart from the aforesaid, we have carefully perused the discussion made by the AO in the draft assessment order and find that no specific reason has been propounded to demonstrate that the profits declared in the Guwahati unit was otherwise untrue except by comparing it with the level of profit of the Pondicherry unit, which ostensibly was not manufacturing the same commodity. Under these circumstances, in our view, there is no merit in the ground raised by the Revenue challenging the direction of the DRP for allowing the claim for deduction under section 80-IC of the Act for Guwahati units in accordance with the claim made in the return of income. - Decided against revenue
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