Tribunal held that while calculating the deduction, profit on each undertaking has to be treated separately. Profits and losses of all eligible undertakings are not to be netted for purpose of calculating deduction. Each undertaking are to be taken on a stand-alone basis. Assessee availed deduction for a period of 5 years at rate of 100 per cent on substantial expansion, deduction for remaining 5 assessment years will be at rate of 30 per cent and not at rate of 100 per cent. (AY. 2010-11 to 2012-13)
Milestone Gears (P.) Ltd. v. ACIT (2019) 174 ITD 702 / 176 DTR 59/ 198 TTJ 870 (Chd.) (Trib.)
S. 80IC : Special category States-Profit on each undertaking has to be treated separately-Profits and losses of all eligible undertakings are not to be netted for purpose of calculating deduction – Each undertaking are to be taken on a stand-alone basis -Where the assessee availed deduction for a period of 5 years at rate of 100 per cent on substantial expansion , deduction for remaining 5 assessment years will be at rate of 30 per cent and not at rate of 100 per cent. [S. 80IC (2), 80IC(5), 80IC(7)]