1992 (3) TMI 17

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....INGHAL J. -In this application under section 256(2) of the Income-tax Act, 1961, the following question has been submitted: "Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in confirming the direction of the Commissioner of Income-tax (Appeals) that the amount of 20% has to be calculated with reference to the profit and loss account of....

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....ordships of the Supreme Court in the case of Distributors (Baroda) P. Ltd. v. Union of India [1985] 155 ITR 120 and CIT v. Kerala Solvent Extractions Ltd. [1987] 165 ITR 174 (Ker), wherein it has been held that 20% deduction under section 80HH can be availed of after setting off unabsorbed depreciation and development rebate, etc. Without going into the merits of the case, we are of the opinion....