Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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The case involves a dispute regarding the eligibility of deduction u/s 80IB for profits derived from repairs and maintenance services of moulds in an industrial undertaking. The court held that to qualify for the deduction, the industrial undertaking must derive profits from the manufacture or production of any article or thing. The receipts from repairs and maintenance were found to lack a direct nexus with the manufacturing activity, as evidenced by the absence of related contracts or documentation. Therefore, the profits from repairs and maintenance were deemed ineligible for deduction u/s 80IB, emphasizing that the deduction is limited to profits derived from the actual manufacturing or production activity of the industrial undertaking.
The case involves a dispute regarding the eligibility of deduction u/s 80IB for profits derived from repairs and maintenance services of moulds in an industrial undertaking. The court held that to qualify for the deduction, the industrial undertaking must derive profits from the manufacture or production of any article or thing. The receipts from repairs and maintenance were found to lack a direct nexus with the manufacturing activity, as evidenced by the absence of related contracts or documentation. Therefore, the profits from repairs and maintenance were deemed ineligible for deduction u/s 80IB, emphasizing that the deduction is limited to profits derived from the actual manufacturing or production activity of the industrial undertaking.
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