https://www.taxtmi.com/caselaws?id=762744 Delhi HC held that a second unit (NOIDA-II) was entitled to deduction under Section 10A as it constituted a separate undertaking, not merely an extension of the first unit. The court noted doubled seating capacity, separate space rental, and additional asset investment. Revenue's acceptance of the unit's eligibility in initial years precluded re-agitation without changed circumstances. Regarding transfer pricing, the court ruled ALP determination should be at enterprise level rather than unit-wise, as external comparables were entity-level and a single agreement governed services across units. The payroll tax liability crystallized upon reconciliation in July 2003. All issues decided favoring the assessee. en-us Tue, 03 Dec 2024 00:00:00 +0530 Fri, 06 Dec 2024 08:47:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762744 Delhi HC held that a second unit (NOIDA-II) was entitled to deduction under Section 10A as it constituted a separate undertaking, not merely an extension of the first unit. The court noted doubled seating capacity, separate space rental, and additional asset investment. Revenue's acceptance of the unit's eligibility in initial years precluded re-agitation without changed circumstances. Regarding transfer pricing, the court ruled ALP determination should be at enterprise level rather than unit-wise, as external comparables were entity-level and a single agreement governed services across units. The payroll tax liability crystallized upon reconciliation in July 2003. All issues decided favoring the assessee. Case-Laws Income Tax Tue, 03 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762744