https://www.taxtmi.com/caselaws?id=790571 Section 10B deduction for a 100% export-oriented undertaking cannot be restricted under section 80-IA(10) merely because its profits are higher than a sister concern's. The anti-abuse provision applies only where there is a close connection and the business is shown to have been arranged so as to earn more than ordinary profits. A mere margin comparison, without a clear finding of such an arrangement or a lawful benchmark for ordinary profit, is insufficient. Extraordinary profits alone do not establish profit shifting, and year-end amalgamation by itself does not prove the arrangement. en-us Thu, 23 Apr 2026 00:00:00 +0530 Mon, 27 Apr 2026 08:21:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790571 Section 10B deduction for a 100% export-oriented undertaking cannot be restricted under section 80-IA(10) merely because its profits are higher than a sister concern's. The anti-abuse provision applies only where there is a close connection and the business is shown to have been arranged so as to earn more than ordinary profits. A mere margin comparison, without a clear finding of such an arrangement or a lawful benchmark for ordinary profit, is insufficient. Extraordinary profits alone do not establish profit shifting, and year-end amalgamation by itself does not prove the arrangement. Case-Laws Income Tax Thu, 23 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790571