https://www.taxtmi.com/caselaws?id=469236 For section 10A computation, telecommunication and link charges excluded from export turnover must also be excluded from total turnover to avoid distortion, and deduction is to be recomputed accordingly. Pre-commencement expenditure for the Pune and Hyderabad SEZ units was treated as revenue business expenditure, with section 14A held inapplicable on the stated reasoning and section 37(1) applied to the Hyderabad unit. Excess section 244A interest was held to require adjustment in the earlier year in which it was brought to tax, with recomputation directed. Levy of section 234C interest was left for examination in accordance with law. Transfer pricing adjustment on reimbursements and intra-group services was rejected on the consistency and pass-through-cost reasoning. en-us Fri, 23 May 2025 00:00:00 +0530 Tue, 09 Jun 2026 12:47:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469236 For section 10A computation, telecommunication and link charges excluded from export turnover must also be excluded from total turnover to avoid distortion, and deduction is to be recomputed accordingly. Pre-commencement expenditure for the Pune and Hyderabad SEZ units was treated as revenue business expenditure, with section 14A held inapplicable on the stated reasoning and section 37(1) applied to the Hyderabad unit. Excess section 244A interest was held to require adjustment in the earlier year in which it was brought to tax, with recomputation directed. Levy of section 234C interest was left for examination in accordance with law. Transfer pricing adjustment on reimbursements and intra-group services was rejected on the consistency and pass-through-cost reasoning. Case-Laws Income Tax Fri, 23 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469236