Manufacturing scrap generated in the ordinary manufacturing...

Manufacturing scrap generated in the ordinary manufacturing process and directly connected with goods produced by eligible undertakings qualifies for profit-linked deduction. Additional exempt-income expenditure cannot be disallowed through a mechanical formula without recorded dissatisfaction, having regard to the accounts, with the voluntary disallowance; no further disallowance was warranted where it exceeded exempt dividend income. Corporate guarantees to associated enterprises are international transactions, with guarantee commission restricted to 0.35% under consistent prior-year treatment; consistency also precluded notional interest on unchanged equity contributions. Common-expense allocation under an established incremental approach was accepted. Royalty benchmarking was remitted for a fresh arm's-length review after disclosure of the search strategy and hearing, while a challenge without an underlying adjustment was redundant.