https://www.taxtmi.com/caselaws?id=782758 HC upheld ITAT's dismissal of Revenue's appeals, confirming the CIT(A)'s deletion of disallowance of deduction u/s 10A for AYs 2007-08 and 2008-09. It was held that the AO's reallocation of royalty and management fee expenses, incurred by non-10A units and paid to an associated foreign entity under a licence and services arrangement, to 10A units based on revenue proportion was unjustified. The AO was also not justified in further loading legal and professional expenses onto 10A units beyond their actual incurrence. Consequently, the assessee's original allocation stood accepted and full eligible deduction u/s 10A was restored. en-us Mon, 24 Nov 2025 00:00:00 +0530 Tue, 02 Dec 2025 15:19:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782758 HC upheld ITAT's dismissal of Revenue's appeals, confirming the CIT(A)'s deletion of disallowance of deduction u/s 10A for AYs 2007-08 and 2008-09. It was held that the AO's reallocation of royalty and management fee expenses, incurred by non-10A units and paid to an associated foreign entity under a licence and services arrangement, to 10A units based on revenue proportion was unjustified. The AO was also not justified in further loading legal and professional expenses onto 10A units beyond their actual incurrence. Consequently, the assessee's original allocation stood accepted and full eligible deduction u/s 10A was restored. Case-Laws Income Tax Mon, 24 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782758