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In a possible carve out from landmark IPCA ruling the High Court of Madras in [2022] 441 ITR 171 (Mad) held that in the case of multiple units enterprise each of the units have to be considered independently for the purpose of working out the relief under section 80HHC. That is subject however to the condition that each of the unit had maintained their accounts independently and there was no interdependency or interlacing of funds to treat them as one consolidated unit and that the gross total income is positive.
This principle may also sail in computing relief under other sections as as 80-IA, 10A, 10AA, 10B etc., in the absence of anything to the contrary in those sections.

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