https://www.taxtmi.com/caselaws?id=471989 Business welfare and ordinary write-off claims require evidence-based assessment rather than unsupported ad hoc disallowance. A non-compete payment that protects commercial use of an acquired trademark constitutes a depreciable business or commercial right. Costs may be allocated to section 80IB-eligible units only where they have a direct operational or product-specific nexus; general corporate costs, head-office depreciation, and further foreign-travel allocations unsupported by such nexus should not reduce unit profits. Finance costs, R&D allocation, and the interaction of sections 80HHC and 80IB require verification of unit-wise facts and computations. Corporate guarantee pricing requires year-specific transfer-pricing benchmarking, not reliance solely on a subsequent year's rate. en-us Fri, 11 Apr 2025 00:00:00 +0530 Fri, 25 Sep 2026 20:15:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471989 Business welfare and ordinary write-off claims require evidence-based assessment rather than unsupported ad hoc disallowance. A non-compete payment that protects commercial use of an acquired trademark constitutes a depreciable business or commercial right. Costs may be allocated to section 80IB-eligible units only where they have a direct operational or product-specific nexus; general corporate costs, head-office depreciation, and further foreign-travel allocations unsupported by such nexus should not reduce unit profits. Finance costs, R&D allocation, and the interaction of sections 80HHC and 80IB require verification of unit-wise facts and computations. Corporate guarantee pricing requires year-specific transfer-pricing benchmarking, not reliance solely on a subsequent year's rate. Case-Laws Income Tax Fri, 11 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471989