Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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.
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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