ITAT partly allowed the assessee's appeal and partly allowed Revenue's appeal. It upheld CIT(A)'s deletion of disallowance relating to reallocation of employee expenses to the Guwahati unit for deduction under section 80IE, holding the assessee's scientific allocation method could not be substituted by the AO. On MAT, ITAT reversed CIT(A) and held excise duty refund of the Guwahati unit is "income" under section 2(24)(xviii) and must be included in book profit under section 115JB. Disallowance of a portion of channel partner/retail promotion and conference expenses under Explanation 1 to section 37(1) was sustained. ITAT allowed indexation while computing book profit in respect of long-term capital gains. The claim under section 80JJAA was remanded to CIT(A) for fresh adjudication on merits.
ITAT partly allowed the assessee's appeal and partly allowed Revenue's appeal. It upheld CIT(A)'s deletion of disallowance relating to reallocation of employee expenses to the Guwahati unit for deduction under section 80IE, holding the assessee's scientific allocation method could not be substituted by the AO. On MAT, ITAT reversed CIT(A) and held excise duty refund of the Guwahati unit is "income" under section 2(24)(xviii) and must be included in book profit under section 115JB. Disallowance of a portion of channel partner/retail promotion and conference expenses under Explanation 1 to section 37(1) was sustained. ITAT allowed indexation while computing book profit in respect of long-term capital gains. The claim under section 80JJAA was remanded to CIT(A) for fresh adjudication on merits.
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