PCIT v. Reckitt Benckiser Healthcare India Ltd. (2023)451 ITR 403 (Guj.)(HC)

S. 80IC : Special category States-Eligible business profits-Fluctuation of the rate of foreign exchange-Excise duty refund-Sale of scrap generated in the manufacturing process-Eligible for the deduction. [S. 10A, 56]

Dismissing the appeal of the Revenue the Court held that the Tribunal did not err in deleting the disallowance made on account of deduction on foreign exchange gain, refund of excise duties paid on material and other items purchased for manufacturing purposes holding that the excess duty refund did not represent the income with the first degree of nexus with the manufacturing profits, and the value of scrap generated in the manufacturing process. (AY.2009-10)