Court Rules Against Apportioning R&D and ESOP Costs to Tax-Exempt Units u/ss 10B, 80IB, 80IC.

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....R & D expenditure and ESOP expenses - apportionment of cost to the units which claimed exemption u/s 10B, 80IB and 80IC - there is nothing on record to show that all the R & D inventions / patents were never sold in outside market but only captively utilised in the exempted units. - apportioning R & D expenditure and ESOP cost not justified.....