Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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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