https://www.taxtmi.com/caselaws?id=400226 Section 10A requires profits to be computed at the undertaking level under the statutory formula, so domestic profits of the same eligible unit are not separately carved out for taxation. Foreign travel costs were treated as allowable business expenditure where they were incurred for development, training, and overseas meetings and the commercial nexus was established. Legal and professional fees connected with prospecting, overseas expansion, branch setup, and related commercial support were also regarded as business deductions rather than capital outgoings. In transfer pricing, the analysis accepted capacity under-utilisation and start-up constraints as relevant commercial factors, and the adjustment was not sustained where the record supported the assessee's approach. en-us Wed, 28 Oct 2020 00:00:00 +0530 Sat, 31 Oct 2020 16:12:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=400226 Section 10A requires profits to be computed at the undertaking level under the statutory formula, so domestic profits of the same eligible unit are not separately carved out for taxation. Foreign travel costs were treated as allowable business expenditure where they were incurred for development, training, and overseas meetings and the commercial nexus was established. Legal and professional fees connected with prospecting, overseas expansion, branch setup, and related commercial support were also regarded as business deductions rather than capital outgoings. In transfer pricing, the analysis accepted capacity under-utilisation and start-up constraints as relevant commercial factors, and the adjustment was not sustained where the record supported the assessee's approach. Case-Laws Income Tax Wed, 28 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400226