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Transpek Silox Industry Ltd.,, Baroda vs The Acit.,Range-4,, Baroda on 28 December, 2017 cites

Prestige Foods Limited vs Deputy Commissioner Of Income Tax on 27 November, 1996

7. As far as the decision of the Madhya Pradesh High Court reported in (2012)81 CCH 031 PRESTIGE FOODS LIMITED v. CIT, is concerned, the assessee did not furnish the expenses incurred by the units for the purpose of considering the deducibility. The Madhya Pradesh High Court viewed that in the absence of any details being made available by the assessee to establish that the particular expenses were incurred for its particular unit out of its two units, the expenses had to be treated as one for both the units which has to be divided based on the proportionate to the turnover. The question that arises for consideration is not the same as had been considered in the Madhya Pradesh High Court. It is not denied by the Revenue that assessee's units have separate accounts indicating their income and the expenses. The assesseee does not claim any deduction on the expenses incurred by the Head Office. The only question is us to whether the common expenses incurred by the Head Office for the purpose of maintaining the units would nevertheless be subjected to the doctrine of proportionality for the purpose of deduction.
Income Tax Appellate Tribunal - Indore Cites 35 - Cited by 14 - Full Document
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