Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
For deduction claims of eligible industrial units, only expenditure having a direct nexus with that undertaking can be reduced from profits; common R&D costs cannot be allocated to the units absent proof that they relate to those units. The Court accepted the Tribunal's factual finding that the R&D projects were unrelated to the products manufactured by the deduction-claiming units, were future-oriented and uncertain, and were not shown by the Assessing Officer to pertain to those units. In the absence of nexus, the allocation-based disallowance was unwarranted, no substantial question of law arose, and the Revenue's challenge was rejected.
For deduction claims of eligible industrial units, only expenditure having a direct nexus with that undertaking can be reduced from profits; common R&D costs cannot be allocated to the units absent proof that they relate to those units. The Court accepted the Tribunal's factual finding that the R&D projects were unrelated to the products manufactured by the deduction-claiming units, were future-oriented and uncertain, and were not shown by the Assessing Officer to pertain to those units. In the absence of nexus, the allocation-based disallowance was unwarranted, no substantial question of law arose, and the Revenue's challenge was rejected.
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