https://www.taxtmi.com/caselaws?id=216246 Deduction under Sections 80-IA and 80-IB was supported where the Silvassa unit was shown to be a genuine software development unit, with industrial registration, verified sales-tax exemption and business turnover records; short duration of operations and high profit margins alone were insufficient to negate the claim. The same reasoning applied to the assessment year covered by Section 80-IB, and the Revenue's allegation of profit diversion was not accepted. A settlement payment made to secure commercial rights, including intellectual property and customer restraints, was treated as capital expenditure because it conferred an enduring commercial advantage, so deduction was disallowed. en-us Wed, 01 Aug 2012 00:00:00 +0530 Tue, 04 Sep 2012 10:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216246 Deduction under Sections 80-IA and 80-IB was supported where the Silvassa unit was shown to be a genuine software development unit, with industrial registration, verified sales-tax exemption and business turnover records; short duration of operations and high profit margins alone were insufficient to negate the claim. The same reasoning applied to the assessment year covered by Section 80-IB, and the Revenue's allegation of profit diversion was not accepted. A settlement payment made to secure commercial rights, including intellectual property and customer restraints, was treated as capital expenditure because it conferred an enduring commercial advantage, so deduction was disallowed. Case-Laws Income Tax Wed, 01 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216246