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    <title>2024 (4) TMI 1416 - ITAT MUMBAI</title>
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    <description>In computing deduction under section 80IA, only expenses with a direct nexus to the eligible undertaking can be loaded to its profits, so general corporate office costs, head office depreciation and non-specific corporate advertisement expenses were not allocable to the units. Ad hoc disallowance of staff welfare expenditure for lunch, refreshments, tea and coffee was also unsustainable where the entertainment-expense restriction had been omitted and no business-purpose defect was shown. Interest attributed to an alleged working-capital deficit of the Goa undertaking was deleted because the deficit was assessed selectively and the assessee showed sufficient own funds. A purely legal additional ground on lease rent and depreciation was admitted and dealt with for statistical purposes.</description>
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      <description>In computing deduction under section 80IA, only expenses with a direct nexus to the eligible undertaking can be loaded to its profits, so general corporate office costs, head office depreciation and non-specific corporate advertisement expenses were not allocable to the units. Ad hoc disallowance of staff welfare expenditure for lunch, refreshments, tea and coffee was also unsustainable where the entertainment-expense restriction had been omitted and no business-purpose defect was shown. Interest attributed to an alleged working-capital deficit of the Goa undertaking was deleted because the deficit was assessed selectively and the assessee showed sufficient own funds. A purely legal additional ground on lease rent and depreciation was admitted and dealt with for statistical purposes.</description>
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