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    <title>2021 (9) TMI 1090 - ITAT DELHI</title>
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    <description>Common administrative expenses for computing the section 80IC deduction were allocated among eligible units on turnover, as that method was considered fair and reasonable absent evidence of distortion; allocation by net profit ratio was rejected. The section 14A disallowance under Rule 8D required fresh consideration because the record lacked complete material on exempt income and the factual basis for applying the provision. The first appellate authority was to reconsider the disallowance after hearing the assessee. The Revenue succeeded on the expense-allocation issue, while the section 14A issue was remitted for fresh adjudication.</description>
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      <link>https://www.taxtmi.com/caselaws?id=412745</link>
      <description>Common administrative expenses for computing the section 80IC deduction were allocated among eligible units on turnover, as that method was considered fair and reasonable absent evidence of distortion; allocation by net profit ratio was rejected. The section 14A disallowance under Rule 8D required fresh consideration because the record lacked complete material on exempt income and the factual basis for applying the provision. The first appellate authority was to reconsider the disallowance after hearing the assessee. The Revenue succeeded on the expense-allocation issue, while the section 14A issue was remitted for fresh adjudication.</description>
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