https://www.taxtmi.com/caselaws?id=286712 ITAT AHMEDABAD deleted the transfer-pricing addition to royalty, finding the effective royalty rate (2.3% of ex-factory sale) acceptable. Warranty provisions computed on empirical basis were allowed as deductible. Foreign exchange gains linked to imported raw materials and foreign working-capital were held to be business income eligible for deduction under s.80IB(10). Excise duty refunds were held to have a direct nexus with business and eligible for s.80IB(4) deduction. MAT credit under s.115JAA was allowed inclusive of surcharge and education cess. Consequential additions to book profit under s.115JB were dismissed. en-us Mon, 04 Mar 2019 00:00:00 +0530 Fri, 22 Aug 2025 22:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=286712 ITAT AHMEDABAD deleted the transfer-pricing addition to royalty, finding the effective royalty rate (2.3% of ex-factory sale) acceptable. Warranty provisions computed on empirical basis were allowed as deductible. Foreign exchange gains linked to imported raw materials and foreign working-capital were held to be business income eligible for deduction under s.80IB(10). Excise duty refunds were held to have a direct nexus with business and eligible for s.80IB(4) deduction. MAT credit under s.115JAA was allowed inclusive of surcharge and education cess. Consequential additions to book profit under s.115JB were dismissed. Case-Laws Income Tax Mon, 04 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=286712