https://www.taxtmi.com/caselaws?id=783635 Aftermarket trading expenses for s.80-IC recomputation were held allocable on the basis of aftermarket trading sales ratio, as they were incurred to generate such sales and the issue was covered by binding ITAT precedent in the assessee's own case; Revenue's challenge failed and the assessee's grounds succeeded. Inclusion of arm's length price adjustment on stock transfers to the head office in eligible Parwanoo unit profits was allowed because s.80-IA(12) was inapplicable where the eligible unit continued to be owned and managed by the same assessee despite amalgamation. Disallowance u/s 40(a)(i) for non-deduction u/s 195 on reimbursements to non-residents was deleted since pure reimbursements lacked income character. Royalty was allowed as revenue expenditure as only limited user rights in know-how were obtained without enduring capital benefit, and 10% notional markup for head office marketing services was disallowed. en-us Mon, 15 Dec 2025 00:00:00 +0530 Fri, 19 Dec 2025 08:30:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783635 Aftermarket trading expenses for s.80-IC recomputation were held allocable on the basis of aftermarket trading sales ratio, as they were incurred to generate such sales and the issue was covered by binding ITAT precedent in the assessee's own case; Revenue's challenge failed and the assessee's grounds succeeded. Inclusion of arm's length price adjustment on stock transfers to the head office in eligible Parwanoo unit profits was allowed because s.80-IA(12) was inapplicable where the eligible unit continued to be owned and managed by the same assessee despite amalgamation. Disallowance u/s 40(a)(i) for non-deduction u/s 195 on reimbursements to non-residents was deleted since pure reimbursements lacked income character. Royalty was allowed as revenue expenditure as only limited user rights in know-how were obtained without enduring capital benefit, and 10% notional markup for head office marketing services was disallowed. Case-Laws Income Tax Mon, 15 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783635