Direct expenses should be attributed to the relevant segment,...

Direct expenses should be attributed to the relevant segment, while common expenses may be allocated by segment revenue; segmental results require examination before rejection. For the software development and ITeS segments, a Rs. 200 crore upper turnover filter reflects differences in functions, assets and risks; knowledge-intensive services are not comparable to routine ITeS. Foreign-currency receivables were benchmarked at LIBOR plus 200 basis points, with a 30-day credit period. No section 14A disallowance arose without exempt income for the relevant year; the Finance Act 2022 amendment operates prospectively from assessment year 2022-23. Consultancy fees for integrating related companies' operations were not accepted as business expenditure where the common director had substantial interests in both. Goodwill first arising on amalgamation qualified for depreciation in assessment year 2020-21; the aggregate depreciation restriction could not be applied mechanically, and the Finance Act 2021 exclusion did not govern that year.