2019 (4) TMI 1438

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....his business activities at Haridwar. Holding that these purchases had not been made, the claim of the respondent-assessee for deduction of Rs. 73,91,587 was disallowed, and the respondent-assessee was subjected to tax under the Income Tax Act on the resultant enhanced profit from business. 3. The assessee carried the mater in appeal to the Commissioner of Income Tax (Appeals) who deleted the additions made by the Assessing Officer, allowing them the benefit, under Section 80IC of the Income Tax Act, on the entire eligible income. Aggrieved thereby, the Revenue carried the matter in appeal to the Tribunal. 4. In the order under appeal, the Tribunal observed that the assessee-unit was eligible for deduction u/s 80IC; it was not in dispute t....

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....ner of Income Tax (Appeals) had rightly deleted the deduction u/s 80IC wrongly made by the Assessing Officer on account of inflated purchases. 5. Deduction u/s 80IC of the Income Tax Act is, admittedly, available to the undertaking of the assessee. The deduction therein is 100% of the profits. As has been held both by the Commissioner of Income Tax (Appeals), and the Tribunal, even if a part of the purchases made by the assessee is held ineligible for deduction it would only result in an increase in the profits of the undertaking; and, since the entire profits of an undertaking is eligible for deduction under Section 80IC of the Income Tax Act, it mattered little whether or not a portion of the purchases, effected by the assessee, was disa....