AI Drafter - (New and Powerful) 
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter. 
TaxTMI 
TaxTMI 
Deduction under 80-IC reduced where profit suppression in non-eligible unit found; net profit rate averaged to recompute deduction.
X X X X Extracts X X X X
X X X X Extracts X X X X
....Assessee's claim for deduction under 80-IC was challenged on grounds that profits were overstated in the eligible unit while suppressed in the non-eligible unit. The tribunal rejected explanations based on excise duty and lower repair-and-maintenance, noting excise duty effects are offset by CENVAT credit and both units share management and similar input procurement and product quality; it accepted that lower R&M in the new unit is plausible but insufficient to explain the disparity. Tribunal found some profit suppression in the non-eligible unit, directed AO to apply a 5.83% net profit rate (average of relevant years) to recompute the 80-IC deduction and disallowed the remainder; appeal partly allowed.....