https://www.taxtmi.com/caselaws?id=216812 The HC held that the AO erred in allocating R&D expenses from the head office to individual units based on turnover for the purpose of reducing deductions under Chapter VI-A. The court found no basis to assume the products resulting from the R&D would necessarily be manufactured by those units. It rejected the presumption that only units engaged in manufacturing could benefit from the R&D, recognizing that the enterprise could exploit such benefits through licensing or assignment to third parties. Consequently, the allocation of expenses among units to recalculate deductions under Section 80IA was incorrect. The decision was in favor of the assessee. en-us Wed, 12 Sep 2012 00:00:00 +0530 Wed, 13 Aug 2025 13:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216812 The HC held that the AO erred in allocating R&D expenses from the head office to individual units based on turnover for the purpose of reducing deductions under Chapter VI-A. The court found no basis to assume the products resulting from the R&D would necessarily be manufactured by those units. It rejected the presumption that only units engaged in manufacturing could benefit from the R&D, recognizing that the enterprise could exploit such benefits through licensing or assignment to third parties. Consequently, the allocation of expenses among units to recalculate deductions under Section 80IA was incorrect. The decision was in favor of the assessee. Case-Laws Income Tax Wed, 12 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216812