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    <title>Direct nexus test for R&amp;D expenditure governed profit deduction for eligible units; Revenue&#039;s challenge failed.</title>
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    <description>For deduction claims of eligible industrial units, only expenditure having a direct nexus with that undertaking can be reduced from profits; common R&amp;D costs cannot be allocated to the units absent proof that they relate to those units. The Court accepted the Tribunal&#039;s factual finding that the R&amp;D projects were unrelated to the products manufactured by the deduction-claiming units, were future-oriented and uncertain, and were not shown by the Assessing Officer to pertain to those units. In the absence of nexus, the allocation-based disallowance was unwarranted, no substantial question of law arose, and the Revenue&#039;s challenge was rejected.</description>
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    <pubDate>Mon, 13 Jul 2026 09:18:42 +0530</pubDate>
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      <title>Direct nexus test for R&amp;D expenditure governed profit deduction for eligible units; Revenue&#039;s challenge failed.</title>
      <link>https://www.taxtmi.com/highlights?id=101651</link>
      <description>For deduction claims of eligible industrial units, only expenditure having a direct nexus with that undertaking can be reduced from profits; common R&amp;D costs cannot be allocated to the units absent proof that they relate to those units. The Court accepted the Tribunal&#039;s factual finding that the R&amp;D projects were unrelated to the products manufactured by the deduction-claiming units, were future-oriented and uncertain, and were not shown by the Assessing Officer to pertain to those units. In the absence of nexus, the allocation-based disallowance was unwarranted, no substantial question of law arose, and the Revenue&#039;s challenge was rejected.</description>
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      <pubDate>Mon, 13 Jul 2026 09:18:42 +0530</pubDate>
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