TMI Blog2015 (12) TMI 1757X X X X Extracts X X X X X X X X Extracts X X X X ..... t:- 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 Tribun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nue against the order of ld. Commissioner of Income Tax (Appeals)-VIII, Kolkata dated 12.01.2012 for the assessment year 2006-07 and in the solitary ground raised therein, the Revenue has challenged the action of the ld. CIT(Appeals) in deleting the disallowance made by the Assessing Officer on account of deduction under section 80IC by allocating indirect expenses to the eligible Unit. 2. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re, worked out such expenses allocable to the Sikkim Unit at ₹ 44,16,463/- and restricted the claim of the assesese for deduction under section 80IC of ₹ 12,40,37,788/- to ₹ 11,96,21,325/-. 3. On appeal, the ld. CIT(Appeals) did not agree with the Assessing Officer and allowed the claim of the assesese for deduction under section 80IC at ₹ 12,40,37,788/- observing that n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 reported in 262 ITR 278 and this principle laid down by the Hon ble Supreme Court in the context of income is also applicable for the allocation of expenses as held by the Coordinate Bench of this Tribunal ..... X X X X Extracts X X X X X X X X Extracts X X X X
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