Dismissing the appeal of the revenue the Court held that in the absence of any material to indicate that the methodology for allocation of expenditure followed by the Commissioner (Appeals) and confirmed by the Tribunal was incorrect or perverse, there was no reason to interfere with the factual findings of the Tribunal. Moreover certain limitations are placed by the statute on the quantum of relief allowable in relation to deductions under Chapter VI-A of the Act, in terms of sections 80A(2) and(4), 80AB, 80AC and 80B. These include a mandate that the relief granted shall not exceed the gross total income as defined under section 80B(5). The relief granted had been restricted to the gross total income computed. (AY. 1997-98 to 2002-03 )
CIT v. Swelect Energy Systems Ltd. (2019) 412 ITR 291 (Mad.)(HC)
S. 80IA : Industrial undertakings–Apportionment of expenses between two sets of units—Deduction not exceeding gross total Income—Apportionment of expenses is valid.