https://www.taxtmi.com/caselaws?id=794859 Research and development expenditure may be reduced from the profits of units claiming deduction under sections 80IB and 80IC only where it is incurred for and on behalf of those specific undertakings. The text explains that apportionment is not justified when the research division operates independently, develops unrelated products, and no direct nexus is shown between that expenditure and the eligible manufacturing units. Expenditure relating to other units or the head office cannot be charged against the profits of the eligible undertaking. On that basis, the disallowance founded on such apportionment was deleted, and the Revenue's challenge failed for lack of any substantial question of law. en-us Fri, 03 Jul 2026 00:00:00 +0530 Mon, 13 Jul 2026 09:18:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794859 Research and development expenditure may be reduced from the profits of units claiming deduction under sections 80IB and 80IC only where it is incurred for and on behalf of those specific undertakings. The text explains that apportionment is not justified when the research division operates independently, develops unrelated products, and no direct nexus is shown between that expenditure and the eligible manufacturing units. Expenditure relating to other units or the head office cannot be charged against the profits of the eligible undertaking. On that basis, the disallowance founded on such apportionment was deleted, and the Revenue's challenge failed for lack of any substantial question of law. Case-Laws Income Tax Fri, 03 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794859