https://www.taxtmi.com/caselaws?id=783380 The ITAT partly allowed the assessee's appeal and partly allowed the Revenue's appeal. It upheld CIT(A)'s deletion of disallowance under section 80IE, accepting the assessee's scientific division-wise allocation of employee expenses to the Guwahati unit. On MAT, it reversed CIT(A), holding excise duty refund for the Guwahati unit is "income" under section 2(24)(xviii) and must be included in book profit under section 115JB. It sustained the estimated disallowance of channel partner/retail promotion and conference expenses under Explanation 1 to section 37(1). It allowed indexation while computing book profit on long-term capital gains under section 115JB. On the additional deduction claim under section 80JJAA, it remanded the matter to CIT(A) for adjudication on merits, rejecting a purely technical denial. en-us Tue, 09 Dec 2025 00:00:00 +0530 Mon, 15 Dec 2025 08:39:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783380 The ITAT partly allowed the assessee's appeal and partly allowed the Revenue's appeal. It upheld CIT(A)'s deletion of disallowance under section 80IE, accepting the assessee's scientific division-wise allocation of employee expenses to the Guwahati unit. On MAT, it reversed CIT(A), holding excise duty refund for the Guwahati unit is "income" under section 2(24)(xviii) and must be included in book profit under section 115JB. It sustained the estimated disallowance of channel partner/retail promotion and conference expenses under Explanation 1 to section 37(1). It allowed indexation while computing book profit on long-term capital gains under section 115JB. On the additional deduction claim under section 80JJAA, it remanded the matter to CIT(A) for adjudication on merits, rejecting a purely technical denial. Case-Laws Income Tax Tue, 09 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783380