Profit / losses of all undertakings are to be treated separately while calculating deduction u/s 80IC

Milestone Gears Private Limited Vs ACIT (ITAT Chandigarh)

For the purpose of calculating deduction u/s 80IC, profit of each undertaking should be treated separately and losses from other eligible undertaking should be ignored. Profit and losses of all the eligible undertaking couldn’t be netted off.

Facts –-

Assessee is engaged in the manufacturing of automotive gears and have 5 manufacturing units. Unit I, III, IV and V are eligible for deduction u/s 80IC. Assessee had claimed deduction u/s 80IC in respect of profits earned in Unit-I and Unit-III ignoring the losses of Unit-IV and Unit-V.

AO contended that the assessee was entitled only to the net profits of the eligible undertakings for the purpose of calculating quantum of deduction available u/s 80IC and accordingly netted the same and allowed the deduction thereafter.

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