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    <title>Deduction under 80-IC reduced where profit suppression in non-eligible unit found; net profit rate averaged to recompute deduction.</title>
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    <description>Assessee&#039;s claim for deduction under 80-IC was challenged on grounds that profits were overstated in the eligible unit while suppressed in the non-eligible unit. The tribunal rejected explanations based on excise duty and lower repair-and-maintenance, noting excise duty effects are offset by CENVAT credit and both units share management and similar input procurement and product quality; it accepted that lower R&amp;M in the new unit is plausible but insufficient to explain the disparity. Tribunal found some profit suppression in the non-eligible unit, directed AO to apply a 5.83% net profit rate (average of relevant years) to recompute the 80-IC deduction and disallowed the remainder; appeal partly allowed.</description>
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    <pubDate>Tue, 17 Feb 2026 10:13:12 +0530</pubDate>
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      <title>Deduction under 80-IC reduced where profit suppression in non-eligible unit found; net profit rate averaged to recompute deduction.</title>
      <link>https://www.taxtmi.com/highlights?id=96955</link>
      <description>Assessee&#039;s claim for deduction under 80-IC was challenged on grounds that profits were overstated in the eligible unit while suppressed in the non-eligible unit. The tribunal rejected explanations based on excise duty and lower repair-and-maintenance, noting excise duty effects are offset by CENVAT credit and both units share management and similar input procurement and product quality; it accepted that lower R&amp;M in the new unit is plausible but insufficient to explain the disparity. Tribunal found some profit suppression in the non-eligible unit, directed AO to apply a 5.83% net profit rate (average of relevant years) to recompute the 80-IC deduction and disallowed the remainder; appeal partly allowed.</description>
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      <pubDate>Tue, 17 Feb 2026 10:13:12 +0530</pubDate>
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