Tax benefit sharing under section 80HHC allowed as deductible business expenditure when passed to manufacturers. An export house or trading house holding the prescribed certificate may pass part or all of its export profit tax benefit to a manufacturer; the actual payment so made may be treated as a business expenditure and deducted in computing the intermediary's total income, provided the aggregate of the intermediary's own tax benefit and the amount passed on does not exceed the maximum deduction available, and the intermediary's profits for computing that maximum are determined after accounting for the payment. Payments received by the manufacturer are not includible in its income if supported by the intermediary's certificate.
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Provisions expressly mentioned in the judgment/order text.
Tax benefit sharing under section 80HHC allowed as deductible business expenditure when passed to manufacturers.
An export house or trading house holding the prescribed certificate may pass part or all of its export profit tax benefit to a manufacturer; the actual payment so made may be treated as a business expenditure and deducted in computing the intermediary's total income, provided the aggregate of the intermediary's own tax benefit and the amount passed on does not exceed the maximum deduction available, and the intermediary's profits for computing that maximum are determined after accounting for the payment. Payments received by the manufacturer are not includible in its income if supported by the intermediary's certificate.
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