Weighted deduction under Sec.35B: place of expenditure irrelevant except specific exclusion; apportionment and evidentiary burden required. Entitlement to weighted deduction under Section 35B depends on whether expenditure falls within clause (b) sub clauses; place of expenditure is irrelevant except for explicit exclusions in sub clause (iii). Composite and common expenses may be proportionately apportioned to qualifying activities. The assessee must prove that expenditures are incurred wholly and exclusively for specified activities. The Board agrees with the tribunal's interpretative principles but expresses reservations about specific factual apportionments, notably substantial salary allocations to export activities and treatment of insurance paid to export credit guarantee bodies.
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Weighted deduction under Sec.35B: place of expenditure irrelevant except specific exclusion; apportionment and evidentiary burden required.
Entitlement to weighted deduction under Section 35B depends on whether expenditure falls within clause (b) sub clauses; place of expenditure is irrelevant except for explicit exclusions in sub clause (iii). Composite and common expenses may be proportionately apportioned to qualifying activities. The assessee must prove that expenditures are incurred wholly and exclusively for specified activities. The Board agrees with the tribunal's interpretative principles but expresses reservations about specific factual apportionments, notably substantial salary allocations to export activities and treatment of insurance paid to export credit guarantee bodies.
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