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ITAT held for the assessee that deduction under s.80IC is allowable for the Rudrapur unit: the Tribunal found substantial manufacturing processes and value-addition at Rudrapur, accepted inter-unit transfer pricing and prior excise/service tax registrations as indicia of manufacture, and deleted the AO's protective disallowance. ITAT upheld CIT(A)'s apportionment findings that unit-wise books reflect separate expenses (no cross-charging except minimal audit fee) and affirmed that only the eligible unit's profit/loss is to be considered when computing s.80IC. Deduction under s.80IA for windmill, though claimed during assessment, was allowed. Claims relating to late payment of PF and ESI were dismissed as covered adversely by binding precedent.
ITAT held for the assessee that deduction under s.80IC is allowable for the Rudrapur unit: the Tribunal found substantial manufacturing processes and value-addition at Rudrapur, accepted inter-unit transfer pricing and prior excise/service tax registrations as indicia of manufacture, and deleted the AO's protective disallowance. ITAT upheld CIT(A)'s apportionment findings that unit-wise books reflect separate expenses (no cross-charging except minimal audit fee) and affirmed that only the eligible unit's profit/loss is to be considered when computing s.80IC. Deduction under s.80IA for windmill, though claimed during assessment, was allowed. Claims relating to late payment of PF and ESI were dismissed as covered adversely by binding precedent.
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