https://www.taxtmi.com/caselaws?id=759995 ITAT Mumbai upheld CIT(A)'s decision allowing full deduction under section 80-IE without allocating R&D expenditure to eligible units. The assessee demonstrated that R&D activities were conducted in separate standalone units with independent financials, developing products unrelated to current manufacturing in eligible units. The pharmaceutical R&D process requires 6-10 years before commercial manufacturing, making current R&D expenditure unrelated to present eligible unit operations. The AO's allocation based on sales percentage was rejected as lacking proper nexus between R&D costs and eligible unit products. en-us Thu, 10 Oct 2024 00:00:00 +0530 Mon, 18 Nov 2024 16:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759995 ITAT Mumbai upheld CIT(A)'s decision allowing full deduction under section 80-IE without allocating R&D expenditure to eligible units. The assessee demonstrated that R&D activities were conducted in separate standalone units with independent financials, developing products unrelated to current manufacturing in eligible units. The pharmaceutical R&D process requires 6-10 years before commercial manufacturing, making current R&D expenditure unrelated to present eligible unit operations. The AO's allocation based on sales percentage was rejected as lacking proper nexus between R&D costs and eligible unit products. Case-Laws Income Tax Thu, 10 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759995