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2015 (12) TMI 1757 - AT - Income TaxDisallowance of deduction u/s 80IC by allocating indirect expenses to the eligible Unit - as per revenue profit eligible for deduction under section 80IC is to be worked out after deducting all the direct and indirect expenses - Held that:- The words "derived from" has a narrow meaning, inasmuch as it contemplates first degree connection with the eligible Unit as held, inter alia, by the Hon’ble Supreme Court in the case of Pandian Chemicals Limited [2003 (4) TMI 3 - SUPREME Court] and this principle laid down in the context of income is also applicable for the allocation of expenses as held by the Coordinate Bench of this Tribunal in the case of Balarampur Chini Mills Limited -vs.- DCIT [2011 (7) TMI 1150 - ITAT KOLKATA] wherein held that expenses incurred by the assessee under the general head of Office Expenses, which are not directly incurred for the eligible Unit, cannot be said to have first degree connection with such Unit so as to reduce the same on pro rata basis for computing the profit of such Unit eligible for deduction - Decided against revenue
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