Deduction cannot be allowed merely on consistency or on the basis of mere Footnote in Audited Balance Sheet

Brief of the case: ITAT New Delhi held in Indo Count Industries Ltd Vs DCIT( ITAT New Delhi) that it all depends upon the facts of the case that whether the assesse was eligible to claim exemption u/s 10B for all the units as a single entity or every unit was independently eligible to claim exemption u/s 10B as a separate unit. It could not be decided upon the note given by the assesse as a foot note beneath the audited balance sheet that only 1 unit was eligible to claim exemption u/s 10B and it was not taking any exemption for the 2nd unit. Also it could not be decided on the basis of consis...