ITAT adjudicated a tax dispute concerning expense allocation and ...

Tax Deduction Dispute: ITAT Mandates Precise Expense Allocation and Narrow Interpretation of Export Incentive Income Under Section 80IC

May 16, 2025

Case Laws Income Tax AT

ITAT adjudicated a tax dispute concerning expense allocation and deduction claims under Section 80IC. The tribunal remanded the matter to the Assessing Officer for detailed expense bifurcation between multiple business units, mandating pro-rata allocation for common expenses like audit fees and directors' remuneration. Regarding export incentives and other income, the tribunal interpreted "derived" income narrowly, holding that only directly attributable income from the industrial undertaking qualifies for deduction. The tribunal ultimately upheld the lower authorities' decision, directing consideration of net interest for computing Section 80IC deductions, while providing specific guidelines for expense allocation across different business units.

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ITAT adjudicated a tax dispute concerning expense allocation and ...

Tax Deduction Dispute: ITAT Mandates Precise Expense Allocation and Narrow Interpretation of Export Incentive Income Under Section 80IC

May 16, 2025

Case Laws Income Tax AT

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