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        Case ID :
        Income Tax

        HC upheld ITAT's dismissal of Revenue's appeals concerning...

        Section 10A deduction upheld; royalty and management fee reallocation to captive units rejected, Revenue appeals dismissed for AYs 2007-08, 2008-09

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                HC upheld ITAT's dismissal of Revenue's appeals concerning deduction under Section 10A for AYs 2007-08 and 2008-09. It affirmed the CIT(A)'s finding that the AO was not justified in reallocating royalty and management fee expenses, incurred by non-10A units and paid to an overseas group entity, to 10A-eligible captive units based on revenue apportionment. The HC held that such expenses, linked to third-party revenue and services of group entities, could not be attributed to captive 10A units, and that additional allocation of legal and professional expenses was unwarranted. Consequently, disallowance of Section 10A deduction was rightly deleted and Revenue's appeals were dismissed.
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