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SC referred a split decision regarding deductions under Sections 80HHC and 80IA to a three-judge bench. The court interpreted Section 80IA(9) as restricting the aggregate deductions under heading C of Chapter VI-A to 100% of business profits, without affecting the computation of individual deductions. The provision aims to prevent taxpayers from claiming repeated deductions on the same eligible income. The court endorsed the Bombay HC's interpretation that the restriction applies to deduction allowability rather than gross income computation, ensuring that total deductions do not exceed the eligible business profits.
SC referred a split decision regarding deductions under Sections 80HHC and 80IA to a three-judge bench. The court interpreted Section 80IA(9) as restricting the aggregate deductions under heading C of Chapter VI-A to 100% of business profits, without affecting the computation of individual deductions. The provision aims to prevent taxpayers from claiming repeated deductions on the same eligible income. The court endorsed the Bombay HC's interpretation that the restriction applies to deduction allowability rather than gross income computation, ensuring that total deductions do not exceed the eligible business profits.
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