https://www.taxtmi.com/caselaws?id=437307 Net royalty expenditure, after setting off royalty received, is treated as a common business cost for Section 80IB deduction where the technology is not shown to have been actually exploited by a particular eligible unit. Although the agreement permitted commercial use at the Jammu plant and elsewhere, the evidence did not establish actual exploitation by any manufacturing unit. On that basis, the royalty cost was required to be allocated across the manufacturing units on a reasonable pro rata basis, rather than confined only to the Jammu unit, for computing the deduction. en-us Wed, 26 Apr 2023 00:00:00 +0530 Wed, 03 May 2023 08:59:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437307 Net royalty expenditure, after setting off royalty received, is treated as a common business cost for Section 80IB deduction where the technology is not shown to have been actually exploited by a particular eligible unit. Although the agreement permitted commercial use at the Jammu plant and elsewhere, the evidence did not establish actual exploitation by any manufacturing unit. On that basis, the royalty cost was required to be allocated across the manufacturing units on a reasonable pro rata basis, rather than confined only to the Jammu unit, for computing the deduction. Case-Laws Income Tax Wed, 26 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437307