Section 80-IB deduction upheld where separate unit accounts and turnover-based expense allocation showed no profit inflation.

Deduction under Section 80-IB was sustained because the assessee kept separate books for the eligible and non-eligible units, directly charged unit-specific expenses to the respective books, and apportioned common expenditure by turnover. The authorities found no material showing that expenses of one unit had been wrongly shifted to the other to inflate the eligible unit's profit. Those concurrent findings of fact did not raise any substantial question of law, so the deduction claim was upheld.

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Issues: Whether the assessee was entitled to deduction under Section 80-IB on the basis of the allocation of expenses between its Parwanoo and non-Parwanoo units.

Analysis: The authorities below found that the assessee maintained separate books of account for the two units, that expenses exclusively attributable to each unit were directly debited to the respective books, and that common expenditure was apportioned in the ratio of turnover. It was also found that no material had been brought on record to show that any expenditure of one unit had been wrongly charged to the other so as to inflate the profit of the eligible unit. These were concurrent findings of fact.

Conclusion: The findings did not give rise to any substantial question of law, and the assessee's claim was upheld.

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