https://www.taxtmi.com/caselaws?id=800394 Section 80-IC eligible profits require a direct nexus with the eligible undertaking. Transit-insurance recoveries connected with operational assets, and reversals or recoveries of doubtful debts and sundry creditors arising from manufacturing sales or operational liabilities, retain that nexus and are includible. Vendor penalties for contractual breaches lack a direct connection with manufacturing or operations and are excluded. Consultancy payments to UAE and Kenya enterprises without an Indian permanent establishment are not chargeable to tax in India under the applicable treaties' business-profits provisions; Section 195 withholding does not apply, so disallowance under Section 40(a)(ia) is unsustainable. en-us Mon, 21 Sep 2026 00:00:00 +0530 Tue, 06 Oct 2026 08:13:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800394 Section 80-IC eligible profits require a direct nexus with the eligible undertaking. Transit-insurance recoveries connected with operational assets, and reversals or recoveries of doubtful debts and sundry creditors arising from manufacturing sales or operational liabilities, retain that nexus and are includible. Vendor penalties for contractual breaches lack a direct connection with manufacturing or operations and are excluded. Consultancy payments to UAE and Kenya enterprises without an Indian permanent establishment are not chargeable to tax in India under the applicable treaties' business-profits provisions; Section 195 withholding does not apply, so disallowance under Section 40(a)(ia) is unsustainable. Case-Laws Income Tax Mon, 21 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800394