Revenue appeal dismissed, Tribunal decisions upheld on deductions, interest income, exempt investments.

The Court dismissed the revenue's appeal, upholding the Tribunal's decisions on all three issues raised. The deductions under Section 80IB for "common expenses" apportionment and "interest income" on scrap sale were allowed based on established legal principles and previous favorable decisions for the assessee. Additionally, the addition under Section 14A for investments yielding exempt income was deleted by the Tribunal, with the Court finding no error in this decision. The revenue's claims were rejected, and the appeal failed, with the connected application also being dismissed.

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Issues:
1. Deduction under Section 80IB for "common expenses" apportionment
2. Deduction under Section 80IB for "interest income" on scrap sale
3. Addition under Section 14A for investments yielding exempt income

Analysis:

Issue 1: Deduction under Section 80IB for "common expenses" apportionment
The appeal by the revenue challenges the Tribunal's decision to allow deduction under Section 80IB of the Income Tax Act for "common expenses" of a significant amount. The revenue argued that the apportionment was incorrect. However, the Tribunal upheld the deduction, citing the assessee's previous cases and dismissing the revenue's appeal due to unexplained delay. The Court noted that previous decisions favored the assessee, and no legal grounds existed for interference. Therefore, the Tribunal's decision was upheld, and the appeal failed.

Issue 2: Deduction under Section 80IB for "interest income" on scrap sale
The second substantial question of law revolved around the claim for deduction under Section 80IB for "interest income" on the sale of scrap. The Tribunal, following precedent, granted relief to the assessee based on established legal decisions. The Court found no grounds for interference, as the Tribunal's decision aligned with correct legal principles. The revenue's appeal was dismissed, affirming the Tribunal's decision in favor of the assessee.

Issue 3: Addition under Section 14A for investments yielding exempt income
Regarding the third substantial question of law, the Tribunal deleted the addition made by the Assessing Officer under Section 14A for investments yielding exempt income. The Tribunal's decision was based on a favorable decision for the assessee, citing legal precedent. The Court found no error in the Tribunal's order, as it followed the correct legal principle. Consequently, the appeal failed, and the substantial questions of law were answered against the revenue.

In conclusion, the Court dismissed the appeal by the revenue, upholding the Tribunal's decisions on all three substantial issues raised. The legal principles and precedents cited in each issue supported the assessee's position, leading to the rejection of the revenue's claims. The connected application was also dismissed accordingly.

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