As per case facts The assessee company claimed deductions under both Section -IA and Section -HHC of the IT Act The Revenue disallowed the simultaneous claims arguing that Section -IA ... barred deductions under any other provision of Chapter VI-A Heading C to the extent a deduction was allowed under -IA The High Court affirmed the disallowance leading to the appeal in the Supreme Court The question arose whether Section -IA limits the computation of income eligible for deduction under a sister section like -HHC or if it merely restricts the allowability of total aggregate deductions under Heading C of Chapter VI-A to the total profits and gains of the eligible business Finally The Supreme Court answered that Section -IA does not affect the computation of deduction under Section -HHC meaning the deduction allowed under -IA is not first subtracted from the gross total income before computing the -HHC deduction Instead it restricts the overall allowability so that the aggregate deductions claimed under Section -IA and other Heading C provisions do not exceed the total profits and gains of the eligible business