Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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