Grasim Industries Ltd., Mumbai vs Dcit Range 6(3), Mumbai on 13 June, 2023
25.2 After hearing both the sides, we find the AO has only allocated the
expenses but no income was allocated. We find the co-ordinate Bench of the
Tribunal in the case of M/s. Procter & Gamble India Ltd. Vs. DCIT, vide ITA No.
5466/Mum/99 order dated 27th November, 2006 for the A.Y. 1990-91 has held
that head office expense allocated to the units are not to be taken into
consideration for computing the income of the assessee eligible for deduction
u/s. 801 and also u/s 8OHH.