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    <title>2023 (8) TMI 1721 - ITAT DELHI</title>
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    <description>Common head office or indirect advertisement, publicity and business promotion expenses were not to be apportioned to the eligible 80-IC undertaking absent a direct nexus, so the deduction recomputation on that basis was rejected in favour of the assessee. Foreign exchange fluctuation loss linked to import-related manufacturing activity was also held not to be a proper basis for allocation to the eligible unit, and that adjustment was deleted. The section 14A read with Rule 8D(2)(iii) disallowance was struck down because valid satisfaction based on the accounts had not been recorded, with the investments also noted as debt-oriented mutual funds. Fringe benefit tax under section 115JB was remitted for fresh consideration in light of the CBDT circular.</description>
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      <description>Common head office or indirect advertisement, publicity and business promotion expenses were not to be apportioned to the eligible 80-IC undertaking absent a direct nexus, so the deduction recomputation on that basis was rejected in favour of the assessee. Foreign exchange fluctuation loss linked to import-related manufacturing activity was also held not to be a proper basis for allocation to the eligible unit, and that adjustment was deleted. The section 14A read with Rule 8D(2)(iii) disallowance was struck down because valid satisfaction based on the accounts had not been recorded, with the investments also noted as debt-oriented mutual funds. Fringe benefit tax under section 115JB was remitted for fresh consideration in light of the CBDT circular.</description>
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