Dismissing the appeal of the revenue the, Tribunal held that any expenditure wholly and exclusively in relation to scheme of demerger could not be allowed as deduction from profits of business in one go but same had to be amortized for income tax purposes over a period of five years and deduction would be allowed accordingly. There was no pre-condition set out in section 35DD mandating any certification from auditor. Tax auditor indeed did not report this claim u/s. 35DD but tax auditor’s non-report could not disentitle assessee from making a claim which was otherwise legally permissible.  (AY.2012-13).