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2015 (12) TMI 703 - AT - Income TaxDeduction u/s 80IC - as per revenue deduction u/s 80IC can only be allowed after arriving at the gross total income by combining the income of both the units i.e. Noida unit and Roorkee unit and excess deduction claimed by the assessee was rightly denied to him - CIT(A) allowed appeal of the assessee directing AO to consider the profits & gains of Roorkee Unit only for allowing deduction u/s 80IC of the Act and also to determine the losses of NOIDA Unit to be carried forward - Held that:- CIT(A), following the dicta laid down by Hon'ble High Court in the case CIT vs Dewan Krafts (2007 (2) TMI 149 - HIGH COURT , DELHI), held that quantum of deduction u/s 80IA(J) of the Act is to be computed on eligible unit as if eligible unit was the only source of income of the assessee. In the case of CIT vs Sona Koyo Steering Systems Ltd. (2010 (2) TMI 83 - DELHI HIGH COURT ), their lordships also expressed the similar view which supports the conclusion of the first appellate authority. Finally, we reach to a logical conclusion that the CIT(A) granted relief to the assessee on valid reasons - Decided against revenue
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