Programme production and copyright assignment can be separately taxed when the agreement shows distinct production activity on behalf of the broadcast...
Transshipment permission for courier import goods granted subject to customs supervision, bond compliance, sealing, escort and destination acknowledgm...
Section 80-IA(10) can curtail a deduction only where there is a close connection, an arrangement between the parties, and that arrangement produces more than ordinary profits. The Court held that extraordinary profits alone do not prove such an arrangement, and the Tribunal had not recorded a categorical finding of one. It further found that comparing a 100% export-oriented unit with a domestic sister concern was legally unsustainable because statutory benefits and cost structures differed materially, so no proper benchmark of ordinary profit was made. The restriction of the Section 10B deduction on the sister concern's profit margin was therefore quashed and the appeal allowed.
Section 80-IA(10) can curtail a deduction only where there is a close connection, an arrangement between the parties, and that arrangement produces more than ordinary profits. The Court held that extraordinary profits alone do not prove such an arrangement, and the Tribunal had not recorded a categorical finding of one. It further found that comparing a 100% export-oriented unit with a domestic sister concern was legally unsustainable because statutory benefits and cost structures differed materially, so no proper benchmark of ordinary profit was made. The restriction of the Section 10B deduction on the sister concern's profit margin was therefore quashed and the appeal allowed.
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