https://www.taxtmi.com/caselaws?id=277258 Section 80HHC treatment distinguishes the face value of DEPB from profit on its transfer, with the exclusion mechanism applying to the profit element rather than the entire receipt. Sample design and development charges connected with export operations are characterised as export-business receipts, not incidental receipts comparable to brokerage, commission, interest, rent or charges under Explanation (baa). Additional depreciation may be examined on additional evidence at the appellate stage where the claim is verifiable and remand proceedings reveal no adverse material. Royalty under a genuine licensing arrangement may support arm's length pricing where embedded in product prices and supported by the taxpayer's operating margins and transaction profile. en-us Tue, 02 May 2017 00:00:00 +0530 Mon, 08 Aug 2022 16:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277258 Section 80HHC treatment distinguishes the face value of DEPB from profit on its transfer, with the exclusion mechanism applying to the profit element rather than the entire receipt. Sample design and development charges connected with export operations are characterised as export-business receipts, not incidental receipts comparable to brokerage, commission, interest, rent or charges under Explanation (baa). Additional depreciation may be examined on additional evidence at the appellate stage where the claim is verifiable and remand proceedings reveal no adverse material. Royalty under a genuine licensing arrangement may support arm's length pricing where embedded in product prices and supported by the taxpayer's operating margins and transaction profile. Case-Laws Income Tax Tue, 02 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277258