In ACIT vs. Rogini Garments 108 ITD 49, the Chennai Special Bench of the ITAT held that in view of s. 80-IA (9), relief under s. 80-IA had to be deducted from the profits and gains before computing relief u/s 80-HHC. M/s SCM Creations was an intervener in that case and a common judgement was passed. The Madras has reversed the judgement of the Special bench and held that relief u/s 80-IA should not be deducted from profits and gains of business before computing relief u/s 80-HHC.