ITAT Rules on Section 80IC: Follow Past Precedents for Expense Allocation and Allow 30% Deduction Without Offsetting Losses.

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....Deduction u/s 80IC - AO reallocated management fees and remuneration paid to managing director on gross profit basis. ITAT held allocation basis accepted by AO in past assessment years must be followed as per rule of consistency, directing AO to accept assessee's basis of allocation. Set off of loss of non-eligible unit against profit of eligible unit for computing deduction u/s 80IC - Following precedents, ITAT directed AO to allow deduction @30% on eligible unit's profit without setting off losses from other units, overriding provisions of sub-s. (7) of s. 80-IA prohibiting such set-off.....