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PER Dr.O.K.NARAYANAN, VICE PRESIDENT This is a bunch of five appeals, all filed by the Revenue. The relevant assessment years are 2008-09, 2009-10 and 2010-11. The Revenue has filed two appeals in the case of Shri V.N.Devadoss in his individual case for the assessment years 2008-09 and 2009-10. The three remaining appeals are filed in the case of Shri V.N.Devadoss(HUF) for the assessment years 2008-09, 2009-10 and 2010-11.

2. The appeals in the case of Shri V.N.Devadoss in his individual case are directed against the common order passed by the Commissioner of Income-tax(Appeals)-I at Chennai, dated 26-3-2012. These two appeals arise out of the respective assessments completed under section 153A, read with section 143(3) of the Income-tax Act, 1961.

3. The remaining three appeals filed in respect of Shri V.N.Devadoss(HUF) are directed against the common order passed by the Commissioner of Income-tax(Appeals)-I at

-3- ITA 1219 to 1223 of 2012 Chennai, dated 26-3-2012. In these cases the appeals for the assessment years 2008-09 and 2008-09 arise out of the assessments completed under section 153A, read with section 143(3) of the Income-tax Act, 1961. The appeal for the assessment year 2010-11 arises out of the regular assessment completed under section 143(3) of the Act.

47. The next common issue raised by the Revenue is regarding the allocation of administrative expenses. This ground

-33- ITA 1219 to 1223 of 2012 is not raised in appeal No.1221(Mds)/2012 relating to the assessment year 2009-10 in the case of Shri V.N.Devadoss in his individual file. The common ground of the Revenue is that the allocation of administrative expenses between 80IB and non 80IB units was without any basis. The assessee has not allocated the administrative expenses relating to the projects eligible for claiming the deduction under section 80IB and therefore the assessee should have allocated administrative expenses atleast 30% of the total administrative expenditure.