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2021 (4) TMI 639 - AT - Income TaxDisallowance of deduction u/s. 80IC under the head interest and financial charges, common expenses of corporate expenses and common expenses of corporate and plastic division - AO was of the view that the interest expenditure required to be allocated proportionately in the ratio of sales for deduction u/s. 80IC of the Act for the industrial undertaking of the assessee - HELD THAT:- No error in the decision of ld. CIT(A) for allocating common interest & financial charges on the basis of investment. Similar in respect of deleting addition of common head expenses and plastic/corporate division expenses made on sales basis, we do not find any infirmity in the decision of ld. CIT(A) after following the decision of the Co-ordinate Bench as cited above in this order. Taking into consider the finding of the Coordinate Bench in the case of assessee itself on the aforesaid issues, we do not find any reason to interfere in the decision of ld. CIT(A), therefore, this ground of appeal of the revenue is dismissed. Disallowance u/s. 14A - HELD THAT:- Respectfully following the decision of Co-ordinate Bench of the ITAT in the case of the assessee itself for A.Y. 2009-10 and A.Y. 2010-11 [2016 (4) TMI 904 - ITAT AHMEDABAD] the appeal of the Revenue is dismissed. Regarding the appeal of the assessee, we direct the Assessing Officer to decide the issue afresh after examination/verification of the details filed by the assessee as per the direction laid down in the decision of the Co-ordinate Bench of the ITAT in the case of the assessee itself [2016 (4) TMI 904 - ITAT AHMEDABAD] and decision of Hon’ble Gujarat High Court [2017 (5) TMI 1160 - GUJARAT HIGH COURT] Addition on account of foreign exchange fluctuation gain - HELD THAT:- We have gone through the decision of ITAT on the similar issue and identical facts and noticed [2016 (4) TMI 904 - ITAT AHMEDABAD] the issue was decided in favour of the assessee Addition for late contribution to ESIC - HELD THAT:- In view of the decision of Hon’ble Gujarat High Court in the case of Gujarat State Road Transport Corporation [2014 (1) TMI 502 - GUJARAT HIGH COURT], we do not find any merit in the appeal of the assessee and the same stands dismissed.
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