Tribunal held that, where the assessee has, two manufacturing units both are eligible for deduction. One unit earned profit and other unit loss-AO is justified in setting of negative income of one eligible unit against positive income of other eligible unit. The decision of the CIT(A) considering the setting of the negative income of one priority unit with the positive income of the another priority unit before computing the deduction under S. 80IC is upheld. (AY. 2010-11, 2011-12)
Elin Appliances (P.) Ltd. v. DCIT (2018) 173 ITD 122 / 198 TTJ 654/( 2019) 176 DTR 52(Chd.)(Trib.)
S. 80IC : Special category States -Two manufacturing units both are eligible for deduction- One unit earned profit and other unit loss-AO is justified in setting of negative income of one eligible unit against positive income of other eligible unit. [S.80AB, 80IA(5), 80IC(7)]