2017 (10) TMI 1005

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....USTICE AKIL KURESHI) 1. Revenue is in appeal against the judgement of the Income Tax Appellate Tribunal dated 20.09.2016 raising following question for our consideration: "Whether the Appellate Tribunal was right in law and on facts in allowing the deduction of Rs. 6,94,58,479/- u/s. 80IC of the Act for Baddi Units without appreciating the fact that the Assessing Officer has rightly al....

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....eting division and the brand value owned by foreign collaboration should have been disallowed. The CIT (Appeals) as well as the Tribunal both came to a concurrent conclusion that there was no separate marketing division and therefore, there was no transfer of goods from eligible to non-eligible undertaking. Thus, in absence of any separate marketing division, there could not be separation of profi....