Dismissing the appeal of the revenue the Court held that the assessee-unit was eligible for deduction u/s. 80IC; it was not in dispute that the assessee was entitled to the benefit of S. 80IC on the entire eligible income; it was also not in dispute that the AO had granted relief to the assessee, under S.  80IC, qua the sum of ‘73,91,587/-claimed in the return of income; when the profits, for the purposes of S.  80IC, were to be calculated as per S.  28 to 44BB of the Act, the purchases were also covered thereunder; while calculating the profits of any business, purchases were also deductible expenditure; disallowance of purchases resulted in reduction in the purchases amount and, consequently, increase in the profit which would be again be eligible for exemption u/s. 80IC of the Act; it would not increase the income tax liability of the assessee, which would remain the same even if the purchases were disallowed; the contention of the Revenue, that the assessee had not made any claim in the return of income for the amount claimed as deduction and, therefore, the deduction should not be allowed in view of S.  80A(5) of the Income Tax Act, was not sustainable, the entire profit of the assessee was exempt u/s 80IC. Accordingly the order of  the Tribunal is  affirmed.