Deduction u/s 80IC allowable in absence of splitting or reconstruction of existing business

ITO Vs Indica Industries Pvt. Ltd. (ITAT Delhi)

Conclusion: Since assessee had not transferred any old machinery from the existing unit to new unit and the transactions of purchase of raw material from the existing unit were at arm’s length price, deduction u/s 80IC was allowable as there was no splitting up or reconstruction of the business already in existence at Noida Unit.

Held: Assessee started supplying its products to Hero Honda and other customers from the new undertaking at

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