Dismissing the appeal of the revenue the Court held that only be net of interest excluding expenditure incurred in earning such interest income which should be excluded for purpose of deduction. Followed ACG Associated Capsules Pvt. Ltd. v. CIT ( 2012) 343 ITR 89 (SC)
PCIT v. Gujarat Paghuthan Energy Corporation (P.) Ltd. (2019) 263 Taxman 255 (Guj.)(HC) Editorial : SLP of revenue is dismissed, PCIT v. Gujarat Paghuthan Energy Corporation (P.) Ltd. (2019) 263 Taxman 254 (SC)
S. 80IA : Industrial undertakings-Gross or net-Net of interest excluding expenditure incurred in earning such interest income which should be excluded for purpose of deduction.