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TMI Blog2012 (9) TMI 1083X X X X Extracts X X X X X X X X Extracts X X X X ..... revenue in this appeal :- (i) Whether on the facts and in the circumstances of the case and law, the Tribunal was right in holding that deduction u/s. 80HHC should be computed qua each unit and not qua assessee ? (ii) Whether on the facts and in the circumstances of the case and law, the Tribunal was right in holdng that deduction u/s.80IA should not be reduced from profits of business for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... net and gross amount of interest receipts from profits of the business as per clause (baa) of explanation to Section 80HHC ? (vi) Whether on the facts and in the circumstances of the case and law, the Tribunal was right in holding that deduction u/s.80HHC should be allowed on interest of ₹ 23.74 lakhs received on delayed payments from debtors relating to sale to customers ? (vii) Wh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... P. Ltd . (supra). 3. As regards question (iii) is concerned, the finding of fact recorded by the ITAT in para 26 of its order is that insurance receipts on the damaged goods had direct nexus with the income of the undertaking and the same has not been excluded from the profits for the purpose of deduction under Section 80IA in the assessee's own case in the earlier years. There is nothing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ainst the revenue by the decision of this Court in the case of CIT V/s. Grindwell Norton Ltd. reported in [2009] 318 ITR 172 (Bom) . Hence the said question cannot be entertained. 6. As regards question (vii) is concerned, counsel for the parties state that the said question stands answered against the revenue by the decision of this Court in the case of CIT V/s. Pfizer Ltd. reported in [ ..... X X X X Extracts X X X X X X X X Extracts X X X X
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