2017 (10) TMI 1005

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..... (10) TMI 939 - GUJARAT HIGH COURT] Appellate Tribunal was right in law and on facts in allowing the deduction u/s. 80IC of the Act for Baddi Unit as held in the earlier assessment year that there was no separate marketing division and therefore, there was no transfer of goods from eligible to non-eligible undertaking. Thus, in absence of any separate marketing division, there could not be separati .....

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..... following question for our consideration: "Whether the Appellate Tribunal was right in law and on facts in allowing the deduction of ₹ 6,94,58,479/- u/s. 80IC of the Act for Baddi Units without appreciating the fact that the Assessing Officer has rightly allowed the claim only to the extent of profits derived from manufacturing activities and disallowed the rest derived from the marketing .....

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..... came to a concurrent conclusion that there was no separate marketing division and therefore, there was no transfer of goods from eligible to non-eligible undertaking. Thus, in absence of any separate marketing division, there could not be separation of profit and expenditure. It was also found that the brand was owned by the foreign collaboration and there cannot be any profit attributable to such .....

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