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    <title>Shared service cost allocation is deductible where business nexus and reasonable allocation are shown, not one-to-one expense tracing.</title>
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    <description>Shared support cost allocated by a group company was deductible under section 37(1) because the assessee showed actual receipt of services, business benefit, and a reasonable allocation basis. The Tribunal held that disallowance based only on the fact that the expense was centrally incurred and cross-charged was not sustainable, absent concrete material showing the claim was sham, fictitious, inflated, capital, personal, or otherwise inadmissible. Allocation on a workstation basis was treated as a rational and business-oriented key with direct nexus to operations, and no one-to-one correlation of every pooled cost item was required. The addition was deleted.</description>
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    <pubDate>Mon, 30 Mar 2026 08:48:12 +0530</pubDate>
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      <title>Shared service cost allocation is deductible where business nexus and reasonable allocation are shown, not one-to-one expense tracing.</title>
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      <description>Shared support cost allocated by a group company was deductible under section 37(1) because the assessee showed actual receipt of services, business benefit, and a reasonable allocation basis. The Tribunal held that disallowance based only on the fact that the expense was centrally incurred and cross-charged was not sustainable, absent concrete material showing the claim was sham, fictitious, inflated, capital, personal, or otherwise inadmissible. Allocation on a workstation basis was treated as a rational and business-oriented key with direct nexus to operations, and no one-to-one correlation of every pooled cost item was required. The addition was deleted.</description>
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