Dismissing the appeal of the revenue the Court held that , deduction to be allowed on gross income . Followed  CIT v. Modern Terry Towers Ltd (2013) 357 ITR 750 (Bom) (HC) (756)  , court held that principle computing deduction u/s 80HHC of the Act  cannot be imported in to S. 80M of the Act. “ The provisions of section 80HHC are entirely different from those of sections 80M and 80AA. There is no basis for importing the provisions of section 80HHC with section 80M . The same does not lead to a satisfactory computation of the net dividend under section 80M”    ( ITA No. 718 of 2017, dt. 18.06.2019)