Proportionate Allocation Method Valid for Computing Section 36(1)(viii) Deduction When Eligible Business Expenses Not Separately Recorded

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....The HC upheld the assessee's methodology for computing deduction under Section 36(1)(viii) of the I.T. Act. Since the assessee's accounts did not segregate actual expenditure for eligible business, the court approved the proportionate allocation method where the ratio of total income to total expenditure was applied to eligible business income to determine eligible business expenses. This approach was justified as the accounts showed gross income and expenditure for the entire business, as well as gross income for eligible business, but not specific expenditure for eligible business. The court confirmed that 20% of the resulting profit figure from eligible business qualified for deduction under Section 36(1)(viii).....