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As per case facts... The assessee company claimed deductions under both Section 80-IA and Section 80-HHC of the IT Act. The Revenue disallowed the simultaneous claims, arguing that Section 80-IA(9)
...barred deductions under any other provision of Chapter VI-A, Heading C to the extent a deduction was allowed under 80-IA. The High Court affirmed the disallowance, leading to the appeal in the Supreme Court. The question arose whether Section 80-IA(9) limits the computation of income eligible for deduction under a sister section like 80-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 80-IA(9) does not affect the computation of deduction under Section 80-HHC (meaning the deduction allowed under 80-IA is not first subtracted from the gross total income before computing the 80-HHC deduction). Instead, it restricts the overall allowability so that the aggregate deductions claimed under Section 80-IA and other Heading C provisions do not exceed the total profits and gains of the eligible business
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