https://www.taxtmi.com/caselaws?id=277258 The article discusses four tax issues: under Section 80HHC, DEPB receipts are to be split between face value and profit on transfer, and only the profit element is relevant for the exclusion mechanism; receipts from sample design and development charges, being integral to export operations, are not incidental receipts covered by Explanation (baa); additional depreciation under Section 32(1)(iia) may be allowed on appellate verification where additional evidence is admitted and no adverse material emerges; and a royalty payment under a genuine licensing arrangement cannot be benchmarked at nil arm's length merely because it is linked to sales when the assessee's margins and transaction profile support the claim. 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 The article discusses four tax issues: under Section 80HHC, DEPB receipts are to be split between face value and profit on transfer, and only the profit element is relevant for the exclusion mechanism; receipts from sample design and development charges, being integral to export operations, are not incidental receipts covered by Explanation (baa); additional depreciation under Section 32(1)(iia) may be allowed on appellate verification where additional evidence is admitted and no adverse material emerges; and a royalty payment under a genuine licensing arrangement cannot be benchmarked at nil arm's length merely because it is linked to sales when the assessee's margins and transaction profile support the claim. Case-Laws Income Tax Tue, 02 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277258