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    <title>2015 (1) TMI 1501 - ITAT CHANDIGARH</title>
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    <description>Deduction under section 80IC was examined on three computation issues. The Tribunal upheld a limited restriction under section 80IA(10) only to the extent of the differential linked to alleged inflated purchases from sister concerns, after rejecting the Assessing Officer&#039;s broad percentage-based approach. It deleted re-estimation of royalty paid for use of the brand name because the payment was supported by agreement, had been accepted in an earlier year, and was not shown to be an inflated profit-shifting device. It also sustained reduction of notional partner&#039;s remuneration from eligible profits, holding that deductions under Chapter VI-A must be computed on profits determined in accordance with the Act, even if the amount was not debited in the profit and loss account.</description>
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      <description>Deduction under section 80IC was examined on three computation issues. The Tribunal upheld a limited restriction under section 80IA(10) only to the extent of the differential linked to alleged inflated purchases from sister concerns, after rejecting the Assessing Officer&#039;s broad percentage-based approach. It deleted re-estimation of royalty paid for use of the brand name because the payment was supported by agreement, had been accepted in an earlier year, and was not shown to be an inflated profit-shifting device. It also sustained reduction of notional partner&#039;s remuneration from eligible profits, holding that deductions under Chapter VI-A must be computed on profits determined in accordance with the Act, even if the amount was not debited in the profit and loss account.</description>
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