Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
