Independent Chapter VI-A deductions: simultaneous Section 80-IB and Section 80HHC relief allowed subject to eligible profit ceiling.

Deductions under Section 80-IB and Section 80HHC were treated as independent Chapter VI-A deductions and could be claimed on the same profits. Section 80-IA(9), read with Section 80-IB(13), was interpreted as restricting only a further deduction to the extent profits had already been allowed under that provision, not as barring deductions under other independent provisions. The Court also noted that the aggregate deduction must remain within the total eligible profits and gains. On that basis, simultaneous relief under Section 80-IB and Section 80HHC was held permissible, subject to the overall ceiling, in favour of the assessee.

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Issues: Whether deduction under Section 80-IB and Section 80HHC of the Income-tax Act, 1961 can both be allowed in respect of the same profits in view of Section 80-IA(9) read with Section 80-IB(13) of the Income-tax Act, 1961.

Analysis: The Court applied the earlier decision holding that deductions under different provisions in Chapter VI-A falling under the heading of deductions in respect of certain incomes are independent of each other. It held that Section 80-IA(9) restricts a further deduction only to the extent profits are already allowed under that provision, and does not require denial of deductions under other independent provisions such as Section 80HHC and Section 80-IB. The overall deduction, however, must remain confined to the total eligible profits and gains.

Conclusion: The simultaneous claim to deduction under Section 80-IB and Section 80HHC was held permissible, subject to the overall ceiling of eligible profits, and the answer was given in favour of the assessee.

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