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TMI Blog2019 (8) TMI 624X X X X Extracts X X X X X X X X Extracts X X X X ..... not arise. Dis-allowance under Section 14 A - HELD THAT:- Decision of Godrej Boyce Manufacturing company ltd. Vs. Deputy Commissioner of Income Tax Anr. [ 2017 (5) TMI 403 - SUPREME COURT] covers the question of dis-allowance against the revenue under Section 14 A. ALP determination and adjustment , the question does not arise in view of the recent decision of this Court in Pr. Commissioner of Income Tax, Udaipur Vs. M/s Secure Meters Ltd., E-Class, Pratapnagar Industrial Area, Udaipur [ 2019 (8) TMI 512 - RAJASTHAN HIGH COURT] Adjustment on account of the corporate guarantee provided by the assessee to its A.E , does not arise. The reasoning is that such corporate guarantee is part of the commercial activity of the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ffice used also for activities of different eligible industrial undertaking for computing deduction u/s 80 IB / 80 IC? 5. Whether on the facts and in law the ld. ITAT was justified in deleting the apportionment of expenses on product development for activities of different eligible industrial undertaking for computing deduction u/s 80IB / 80IC? 3. Mr.Anjay Kothari accepts notice on behalf of the respondents. 4. The other questions of law urged are first with respect to justifiability of deduction of certain amount under Section 80 IB/IC as part of trading profits for the bated unit. The second question is with respect to deletion of apportionment of expenses on information system for ac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... housing electronics meters so as to make it convenient for use by the consumers is an activity intrinsically connected with the business qualifying for deduction. As a consequence, it is held that this question of law does not arise. 7. The other two questions in the opinion of this Court relating to service income and apportionment of the expenses, having regard to the concurrent findings do not arise. 8. This Court is further of the opinion that in I.T.Appeal No.74/2017, the additional question urged i.e. adjustment on account of the corporate guarantee provided by the assessee to its A.E, does not arise. The reasoning is that such corporate guarantee is part of the commercial activity o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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