https://www.taxtmi.com/caselaws?id=425847 A consistently accepted and scientifically reasonable method of apportioning common head office and selling expenses was upheld for section 80IB deduction, with the Revenue's challenge failing on consistency grounds. Section 14A read with Rule 8D disallowance was held unsustainable where own funds exceeded investments and no cogent nexus with borrowed funds was shown, so the disallowance was deleted. Scrap generated in the manufacturing process was treated as having a direct nexus with the eligible undertaking and remained deductible under section 80IB. Corporate guarantee to subsidiaries was treated as an international transaction, but the arm's length commission had to be benchmarked realistically and confined to the effective period of the guarantee. en-us Fri, 29 Jul 2022 00:00:00 +0530 Mon, 01 Aug 2022 12:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=425847 A consistently accepted and scientifically reasonable method of apportioning common head office and selling expenses was upheld for section 80IB deduction, with the Revenue's challenge failing on consistency grounds. Section 14A read with Rule 8D disallowance was held unsustainable where own funds exceeded investments and no cogent nexus with borrowed funds was shown, so the disallowance was deleted. Scrap generated in the manufacturing process was treated as having a direct nexus with the eligible undertaking and remained deductible under section 80IB. Corporate guarantee to subsidiaries was treated as an international transaction, but the arm's length commission had to be benchmarked realistically and confined to the effective period of the guarantee. Case-Laws Income Tax Fri, 29 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=425847