Independent computation of Chapter VI-A deductions preserved, while aggregate deductions remain capped at eligible business profits.

Deferred sales tax liability claimed under Section 43B requires fresh examination where subsequent statutory VAT adjustment orders directly address the earlier absence of evidence that the liability was converted into a Government loan. The claim is remitted for determination on that material. Section 80IA(9), applicable to Section 80IB, restricts the aggregate allowance of Chapter VI-A deductions to eligible business profits but does not reduce the profits used to compute Section 80HHC independently. Section 80HHC must therefore be recomputed without reducing the Section 80IB deduction, subject to the aggregate ceiling.

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Issues: (i) Whether deferred sales tax liability qualified for deduction under Section 43B upon production of subsequent statutory adjustment orders; (ii) Whether deduction under Section 80IB must be reduced while computing deduction under Section 80HHC.

Issue (i): Whether deferred sales tax liability qualified for deduction under Section 43B upon production of subsequent statutory adjustment orders.

Analysis: The earlier disallowance rested solely on absence of material showing conversion of the deferred sales tax liability into a Government loan. Form VAT-205 adjustment orders subsequently issued by the competent Commercial Tax Officer were statutory documents unavailable during the assessment and prior appellate proceedings, and directly addressed that evidentiary deficiency. Their effect on entitlement under Section 43B required examination by the Assessing Authority.

Conclusion: The Section 43B claim is remitted for fresh determination after examination of the statutory adjustment orders.

Issue (ii): Whether deduction under Section 80IB must be reduced while computing deduction under Section 80HHC.

Analysis: Section 80IA(9), as applicable to Section 80IB, regulates the allowance of deductions so that their aggregate does not exceed eligible business profits; it does not alter the computation of deduction under Section 80HHC. Deductions under the respective Chapter VI-A provisions must first be computed independently, followed by application of the aggregate ceiling.

Conclusion: Deduction allowed under Section 80IB cannot be reduced while computing deduction under Section 80HHC; the issue is decided in favour of the assessee.

Final Conclusion: The Section 43B claim requires reconsideration on the subsequent statutory material, and the Section 80HHC deduction must be recomputed without reducing the Section 80IB deduction, while ensuring that total deductions do not exceed eligible profits.

Ratio Decidendi: A restriction against double deduction under Section 80IA(9) concerns the ultimate allowance of aggregate deductions and does not reduce the profits used to compute deduction independently under another Chapter VI-A provision.

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