argued that its profit is deductible u/s 80IC of the Act. He vehemently
submitted that once the profit from rendering of software development services ... elaborated that the profit of an assessee,
eligible for deduction under section 80IC , becomes tax neutral irrespective of its
quantum. He, therefore, urged that either
East Region it is eligible to claim deductions u/s. 80IA and 80IC
of the Act for its business of infrastructure, development and manufacturing respectively ... certificate certifying the amount eligible for deduction u/s.
80IA and 80IC of the Act. Scrutiny assessment in respect to original assessment was so
completed
justified in upholding the denial of deduction u/s 80IB and 80IC of the Act in respect of
other income as not eligible thereon ... village-Judikalan, District-Solan,
H.P. and also claimed deduction u/s 80IC of the Act of Rs. 95,44,128/- in respect
return of income, the assessee company had claimed deduction u/s. 80IC and 80IA ... considered. The assessee contended that the issue of
eligibility u/s. 80IC was raised at the time of assessment and the assessee has furnished reply
deletion of addition made on
account of excess claim u/s 80IC of the Act.
Page | 9
ITA No.2296/KOL/2016
(ASSESSMENT YEAR ... amount of Rs.1,72,35,293/- claimed as deduction u/s
80IC of the Act and held the net interest income as declared
disallowing Rs. 60,30,690/- in
the computation of deduction u/s 80IC and such action of the ld. CIT(A) is
wholly ... erred in
directing the A.O. to enhance the deduction u/s 80IC by the amount of
disallowance so made and in view
further submission that the assessee had claimed deduction u/s.
80IC(2) of the Act. It was the submission that on the basis of these ... submitted by the learned DR that the deduction claimed u/s.
80IC(2) of the Act was denied by the Assessing Officer on the ground
account of
disallowance of assessee's claim for deduction under section 80IC to the
extent of Rs.1,04,78,226/-. The said assessment ... Dehradun Unit had inflated its
profit for claiming higher deduction under section 80IC. He also noted
that the profit booked by the assessee-company
manufacturing" within the strict test of eligibility condition
provided u/s 80IC of the I.T. Act, 1961.
2. That, on the facts ... allegedly claimed as deduction u/s 80IC of the I.T.
Act, 1961.
4. That, on the facts and circumstances of the case, the learned
reversing the
assessment findings disallowing assessee's claim of section 80IC deduction
claims involving figures ... amounted to manufacture nor production of any article or thing u/s
80IC(2) and therefore its corresponding deduction claimed of ₹436,98,608/-
resulted
