Zandu Pharmaceuticals Works Ltd. v. CIT

350 ITR 366High Court2013#1676 most cited

What is Zandu Pharmaceuticals Works Ltd. v. CIT authority for?

Expenses, including scientific research or head office expenses, cannot be allocated to units eligible for deductions under sections 80IB or 80IC unless there is a clear nexus between the expenditure and the specific eligible unit for computing the deduction.

68

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Also referred to as

Zandu Pharmaceuticals Works Ltd. v. CIT · section 80IB deduction · section 80IC deduction · allocation of expenses · scientific research expenses · R&D expenditure · nexus with eligible unit · head office expenses · computation of deduction · 350 ITR 366

Also reported as

259 CTR 253

Sections most often in play

Section 80ICSection 80IBSection 92CASection 143(3)Section 115JBSection 144C(3)Section 14ASection 35(2AB)

Issues it is cited on

section 92ba(i)r&d expendituresection 35(1)(iv)section 80ieexport oriented unitsection 100section 6(1)profit split methodbright line testsection 35(2ab)resale price methodsection 36(l)(va)

Judgments citing Zandu Pharmaceuticals Works Ltd. v. CIT

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3991/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

…IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos. 3971 and 3991/MUM/2025 Assessment Years: 2015-16 and 2016-17 Deputy Commissioner of Glenmark Pharmaceuticals Income Tax, Limited Circle-3(4), B/2, Mahalaxmi Chambers, Mumbai Vs. 22 Bhulabhai Desai Road, Mahalaxmi, Cumballa Hill S.O Mumbai - 400026 (PAN: AAACG2207L) (Appellant) (Respondent) Present for: Assessee : Shri Vijay Mehta, CA Revenue : Ms. Neena Jeph, CIT DR Date of Hearing : 15.12.2025 and 22.12.2025 Date of Pronouncement : 12.03.2026 O R D E R PER GIRISH AGRA…

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3971/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Mar 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

…IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos. 3971 and 3991/MUM/2025 Assessment Years: 2015-16 and 2016-17 Deputy Commissioner of Glenmark Pharmaceuticals Income Tax, Limited Circle-3(4), B/2, Mahalaxmi Chambers, Mumbai Vs. 22 Bhulabhai Desai Road, Mahalaxmi, Cumballa Hill S.O Mumbai - 400026 (PAN: AAACG2207L) (Appellant) (Respondent) Present for: Assessee : Shri Vijay Mehta, CA Revenue : Ms. Neena Jeph, CIT DR Date of Hearing : 15.12.2025 and 22.12.2025 Date of Pronouncement : 12.03.2026 O R D E R PER GIRISH AGRA…

M/S. CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeal of the Revenue is partly allowed for statistical purpose and the appeal of the assessee is partly allowed

ITA 383/AHD/2020[2012-13]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

Section 115JSection 144Section 2Section 35Section 36(1)(iii)Section 36(1)(vii)Section 37Section 43BSection 80I

…e three units in question. It thus emerges that the authorities below have adopted adhocism in applying the above turnover formula for allocating the impugned expenditure. Hon'ble Bombay high court's decision in Zhandu Pharmaceutical Works Ltd. vs. CIT (2013) 350 ITR 366 (Bom.) deletes A.Ys. 2004-05 & 2011-12 similar disallowance in absence of non establishment of any nexus between R&D facilities and other units. We find that the authorities below have nowhere arrived at such a nexus in instant case as well. We therefore delete the impugned allocation by adopting the above discussed reasoning. The assessee succee…

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeal of the Revenue is partly allowed for statistical purpose and the appeal of the assessee is partly allowed

ITA 345/AHD/2020[2012-13]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

Section 115JSection 144Section 2Section 35Section 36(1)(iii)Section 36(1)(vii)Section 37Section 43BSection 80I

…e three units in question. It thus emerges that the authorities below have adopted adhocism in applying the above turnover formula for allocating the impugned expenditure. Hon'ble Bombay high court's decision in Zhandu Pharmaceutical Works Ltd. vs. CIT (2013) 350 ITR 366 (Bom.) deletes A.Ys. 2004-05 & 2011-12 similar disallowance in absence of non establishment of any nexus between R&D facilities and other units. We find that the authorities below have nowhere arrived at such a nexus in instant case as well. We therefore delete the impugned allocation by adopting the above discussed reasoning. The assessee succee…

DCIT(CC)-2(4), MUMBAI, MUMBAI vs. MACLEODS PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 3474/MUM/2024[2016-17]Status: DisposedITAT Mumbai28 Oct 2024AY 2016-17

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

For Appellant: Shri Ashok Bansal, CAFor Respondent: Shri Pankaj Kumar, CIT DR
Section 153ASection 35Section 80ISection 92B

…e units and products on which R & D is Macleods Pharmaceuticals Ltd., AY 2013-14 to 2016-17 undertaken were on records which shows that they are completely independent from each other. Assessee placed reliance on the Zandu Pharmaceuticals Works Ltd., v. CIT [350 ITR 366] and various other decisions in support of his contention that R & D expenditure incurred in head office cannot be allocated to the units. We observe from the Assessment Order that the Assessing Officer predominantly stating that R & D expenditure incurred by the assessee is inextricably linked with the business of the assessee including the busi…

DCIT(CC)-2(4), MUMBAI, MUMBAI vs. MACLEODS PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 3473/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Oct 2024AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

For Appellant: Shri Ashok Bansal, CAFor Respondent: Shri Pankaj Kumar, CIT DR
Section 153ASection 35Section 80ISection 92B

…e units and products on which R & D is Macleods Pharmaceuticals Ltd., AY 2013-14 to 2016-17 undertaken were on records which shows that they are completely independent from each other. Assessee placed reliance on the Zandu Pharmaceuticals Works Ltd., v. CIT [350 ITR 366] and various other decisions in support of his contention that R & D expenditure incurred in head office cannot be allocated to the units. We observe from the Assessment Order that the Assessing Officer predominantly stating that R & D expenditure incurred by the assessee is inextricably linked with the business of the assessee including the busi…

DCIT(CC)-2(4), MUMBAI., MUMBAI vs. MACLEODS PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 3472/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Oct 2024AY 2014-15

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

For Appellant: Shri Ashok Bansal, CAFor Respondent: Shri Pankaj Kumar, CIT DR
Section 153ASection 35Section 80ISection 92B

…e units and products on which R & D is Macleods Pharmaceuticals Ltd., AY 2013-14 to 2016-17 undertaken were on records which shows that they are completely independent from each other. Assessee placed reliance on the Zandu Pharmaceuticals Works Ltd., v. CIT [350 ITR 366] and various other decisions in support of his contention that R & D expenditure incurred in head office cannot be allocated to the units. We observe from the Assessment Order that the Assessing Officer predominantly stating that R & D expenditure incurred by the assessee is inextricably linked with the business of the assessee including the busi…

DEPUTY COMMISSIONER OF INCOME TAX, (CC)-2(4), MUMBAI, MUMBAI vs. MACLEODS PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 3471/MUM/2024[2013-14]Status: DisposedITAT Mumbai28 Oct 2024AY 2013-14

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

For Appellant: Shri Ashok Bansal, CAFor Respondent: Shri Pankaj Kumar, CIT DR
Section 153ASection 35Section 80ISection 92B

…e units and products on which R & D is Macleods Pharmaceuticals Ltd., AY 2013-14 to 2016-17 undertaken were on records which shows that they are completely independent from each other. Assessee placed reliance on the Zandu Pharmaceuticals Works Ltd., v. CIT [350 ITR 366] and various other decisions in support of his contention that R & D expenditure incurred in head office cannot be allocated to the units. We observe from the Assessment Order that the Assessing Officer predominantly stating that R & D expenditure incurred by the assessee is inextricably linked with the business of the assessee including the busi…

ITO, NEW DELHI vs. M/S ANSAL HOUSING & CONSTRUCTION LTD., NEW DELHI

In the result, the cross-objection filed by the assessee is dismissed

ITA 2731/DEL/2010[2007-08]Status: DisposedITAT Delhi26 Jul 2024AY 2007-08

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2007-08] Dcit, Vs Ansal Housing & Construction Ltd., Central Circle-20, Ugf-15, Indraprastha Building, 21, New Delhi. Barakhamba Road, New Delhi. Pan-Aaaca0377R Appellant Respondent

Section 143(3)Section 14ASection 80Section 80I

…imilarly, the Courts in the following cases have held that unless the expenditure incurred on the R & D work relates to the undertaking/unit in question, the same cannot be apportioned to it on hypothetical basis: • Zandu Pharmaceuticals Works Limited v. CIT: 350 ITR 366 (Born.) • Bush Boake Allen (India) Ltd. v. CIT: 273 ITR 152 (Mad.) It is further submitted that all the impugned eligible projects were launched in earlier years which stood substantially sold out and were nearing completion during the year under consideration. The details of launch of the project and percentage of completion as at the end of the…

ACIT, CIRCLE- 7(1), NEW DELHI vs. DABUR INDIA LTD., NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purpose

ITA 8273/DEL/2019[2014-15]Status: DisposedITAT Delhi18 Mar 2024AY 2014-15

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiya

…lakhs is concerned, the finding of the Id. CIT(A) that such expenses have no nexus with the units eligible for deduction has not been controverted by the Revenue. We find, the Hon'ble Bombay High Court in the case of Zandu Pharmaceuticals Works Ltd. vs. CIT, 350 ITR 366 (Bom) has held that once the expenses have no nexus with the units eligible for deduction, such expenses cannot be allocated to units for the purpose of computing deduction w/s 80IB/801C of the Act. Since the scientific research expenses of Rs.651 lakhs which were included in the head office expenses allocated by the AO are not connected with the…

DABUR INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE- 7(1), NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purpose

ITA 7775/DEL/2019[2014-15]Status: DisposedITAT Delhi18 Mar 2024AY 2014-15

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiya

…lakhs is concerned, the finding of the Id. CIT(A) that such expenses have no nexus with the units eligible for deduction has not been controverted by the Revenue. We find, the Hon'ble Bombay High Court in the case of Zandu Pharmaceuticals Works Ltd. vs. CIT, 350 ITR 366 (Bom) has held that once the expenses have no nexus with the units eligible for deduction, such expenses cannot be allocated to units for the purpose of computing deduction w/s 80IB/801C of the Act. Since the scientific research expenses of Rs.651 lakhs which were included in the head office expenses allocated by the AO are not connected with the…

ACIT, CIRCLE- 7(1), NEW DELHI vs. DABUR INDIA LTD., NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purpose

ITA 5272/DEL/2019[2013-14]Status: DisposedITAT Delhi18 Mar 2024AY 2013-14

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiya

…lakhs is concerned, the finding of the Id. CIT(A) that such expenses have no nexus with the units eligible for deduction has not been controverted by the Revenue. We find, the Hon'ble Bombay High Court in the case of Zandu Pharmaceuticals Works Ltd. vs. CIT, 350 ITR 366 (Bom) has held that once the expenses have no nexus with the units eligible for deduction, such expenses cannot be allocated to units for the purpose of computing deduction w/s 80IB/801C of the Act. Since the scientific research expenses of Rs.651 lakhs which were included in the head office expenses allocated by the AO are not connected with the…

DABUR INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE- 7(1), NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purpose

ITA 4126/DEL/2019[2013-14]Status: DisposedITAT Delhi18 Mar 2024AY 2013-14

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiya

…lakhs is concerned, the finding of the Id. CIT(A) that such expenses have no nexus with the units eligible for deduction has not been controverted by the Revenue. We find, the Hon'ble Bombay High Court in the case of Zandu Pharmaceuticals Works Ltd. vs. CIT, 350 ITR 366 (Bom) has held that once the expenses have no nexus with the units eligible for deduction, such expenses cannot be allocated to units for the purpose of computing deduction w/s 80IB/801C of the Act. Since the scientific research expenses of Rs.651 lakhs which were included in the head office expenses allocated by the AO are not connected with the…

DCIT, CIRCLE- 7(1), NEW DELHI vs. DABUR INDIA LTD., NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purpose

ITA 4073/DEL/2019[2012-13]Status: DisposedITAT Delhi18 Mar 2024AY 2012-13

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiya

…lakhs is concerned, the finding of the Id. CIT(A) that such expenses have no nexus with the units eligible for deduction has not been controverted by the Revenue. We find, the Hon'ble Bombay High Court in the case of Zandu Pharmaceuticals Works Ltd. vs. CIT, 350 ITR 366 (Bom) has held that once the expenses have no nexus with the units eligible for deduction, such expenses cannot be allocated to units for the purpose of computing deduction w/s 80IB/801C of the Act. Since the scientific research expenses of Rs.651 lakhs which were included in the head office expenses allocated by the AO are not connected with the…

DABUR INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE- 7(1), NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purpose

ITA 3791/DEL/2019[2012-13]Status: DisposedITAT Delhi18 Mar 2024AY 2012-13

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiya

…lakhs is concerned, the finding of the Id. CIT(A) that such expenses have no nexus with the units eligible for deduction has not been controverted by the Revenue. We find, the Hon'ble Bombay High Court in the case of Zandu Pharmaceuticals Works Ltd. vs. CIT, 350 ITR 366 (Bom) has held that once the expenses have no nexus with the units eligible for deduction, such expenses cannot be allocated to units for the purpose of computing deduction w/s 80IB/801C of the Act. Since the scientific research expenses of Rs.651 lakhs which were included in the head office expenses allocated by the AO are not connected with the…

SVP INDUSTRIES LTD.,NEW DELHI vs. ACIT, CIRCLE- 22(2), NEW DELHI

In the result, the appeals of the assessee are partly allowed in the manner as indicated above

ITA 4026/DEL/2019[2013-14]Status: DisposedITAT Delhi13 Oct 2023AY 2013-14

Bench: Shri Chandra Mohan Garg & M.Balaganesh

For Appellant: Shri M.P Rastogi, AdvFor Respondent: Shri Vipul Kashyap, Sr. DR
Section 14ASection 80ASection 80J

…ost division and by considering the depreciation pertaining ETS unit and directed expenses for press mud and bio gas generation only. For above preposition the ld. counsel has relied on following judgments:- (i) Zandu Pharmaceuticals Works Ltd. vs. CIT [2013] 350 ITR 366 (Bom) (ii) M/s. Hindustan Lever Ltd. vs. DCIT Cir 1(1), Mumbai 2012 (2) TMI 571- ITAT Mumbai (iii) CIT vs Jiyajeerao Cotton Mills Ltd. IT Reference No. 600 of 1979 order dated 25th Jan 1990 (iv) National Fertilizers Ltd. [2005] 142 Taxman 5 (AAR) 6. The ld. counsel also submitted that In the case of Zandu Pharmaceuticals Works vs. CIT in 350 ITR…

SVP INDUSTRIES LTD.,NEW DELHI vs. ACIT CIRCLE-22(2), NEW DELHI

In the result, the appeals of the assessee are partly allowed in the manner as indicated above

ITA 4025/DEL/2019[2012-13]Status: DisposedITAT Delhi13 Oct 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & M.Balaganesh

For Appellant: Shri M.P Rastogi, AdvFor Respondent: Shri Vipul Kashyap, Sr. DR
Section 14ASection 80ASection 80J

…ost division and by considering the depreciation pertaining ETS unit and directed expenses for press mud and bio gas generation only. For above preposition the ld. counsel has relied on following judgments:- (i) Zandu Pharmaceuticals Works Ltd. vs. CIT [2013] 350 ITR 366 (Bom) (ii) M/s. Hindustan Lever Ltd. vs. DCIT Cir 1(1), Mumbai 2012 (2) TMI 571- ITAT Mumbai (iii) CIT vs Jiyajeerao Cotton Mills Ltd. IT Reference No. 600 of 1979 order dated 25th Jan 1990 (iv) National Fertilizers Ltd. [2005] 142 Taxman 5 (AAR) 6. The ld. counsel also submitted that In the case of Zandu Pharmaceuticals Works vs. CIT in 350 ITR…

HINDUSTAN UNILEVER LTD,MUMBAI vs. ITO CIR 1(1)(4), MUMBAI

In the result, both the appeal of the assessee and the revenue are partly allowed

ITA 5431/MUM/2011[2001-02]Status: DisposedITAT Mumbai18 Aug 2023AY 2001-02

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 10BSection 80HSection 80I

…xport Unit and Khandla Unit ? 4. Regarding question No. 2 and 3 : (a) We find that the impugned order of the Tribunal allowed the respondent - assessee's appeal before it by following a decision of this Court in Zandu Pharmaceuticals Works Ltd. v. CIT [2013] 350 ITR 366/213 Taxman 207/31 taxmann.com 191. The Tribunal while following the principle in this Court's order in Zandu Pharmaceuticals Works Ltd. (supra) held that so far as research and interest expenses are concerned, it can only be allowed to the extent it has nexus to the unit claiming the deduction. The grievance of the revenue before us is that the a…

THE ASSISTANT COMMISSIONER OF INCOME-TAX-2(1)BHILAI, BHILAI(CG) vs. M/S SMS SHIVNATH INFRASSTRUCTURE PVT LTD., DURG, DURG(CG)

In the result, appeal of the revenue in ITA No

ITA 87/BIL/2017[2012-13]Status: DisposedITAT Raipur27 Mar 2023AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.87/Rpr/2017 (ननधाारण वषा / Assessment Year :2012-2013) Acit-2(1), Bhilai Vs M/S Sms Shivnath Infrastructure Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं./Ita No.107/Rpr/2016 (ननधाारण वषा / Assessment Year :2012-2013) M/S Sms Shivnath Infrastructure Vs Pr.Cit-2, Raipur Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri Kapil Hirani, Adv. & MukeshFor Respondent: Shri Debashis Lahiri, CIT-DR
Section 115JSection 143(3)Section 250(4)Section 36Section 80ISection 80l

…g the course of hearing. 13.6. Expenses not attributable to the eligible business are to be excluded by computing the profits of the eligible business under section 80IA. 13.6.1. The Hon'ble Bombay High Court in Zandu Pharmaceuticals Works Ltd. Vs. CIT (2013) 350 ITR 366 has held that while computing deduction under section 80lA, expenses that do not relate to industrial undertaking 10 ITA No.87/RPR/2017 & ITA No.107/RPR/2016 under consideration, cannot be taken into consideration. There must be a direct nexus between an industrial undertaking and the expenses, which are sought to be apportioned or attributed to…

M/S SMS SHIVNATH INFRASTRUCTURE PVT LTD,DURG(CG) vs. THE PR. COMMISSIONER OF INCOME TAX-2, RAIPUR (CG)

In the result, appeal of the revenue in ITA No

ITA 107/BIL/2016[2011-12]Status: DisposedITAT Raipur27 Mar 2023AY 2011-12

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.87/Rpr/2017 (ननधाारण वषा / Assessment Year :2012-2013) Acit-2(1), Bhilai Vs M/S Sms Shivnath Infrastructure Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं./Ita No.107/Rpr/2016 (ननधाारण वषा / Assessment Year :2012-2013) M/S Sms Shivnath Infrastructure Vs Pr.Cit-2, Raipur Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri Kapil Hirani, Adv. & MukeshFor Respondent: Shri Debashis Lahiri, CIT-DR
Section 115JSection 143(3)Section 250(4)Section 36Section 80ISection 80l

…g the course of hearing. 13.6. Expenses not attributable to the eligible business are to be excluded by computing the profits of the eligible business under section 80IA. 13.6.1. The Hon'ble Bombay High Court in Zandu Pharmaceuticals Works Ltd. Vs. CIT (2013) 350 ITR 366 has held that while computing deduction under section 80lA, expenses that do not relate to industrial undertaking 10 ITA No.87/RPR/2017 & ITA No.107/RPR/2016 under consideration, cannot be taken into consideration. There must be a direct nexus between an industrial undertaking and the expenses, which are sought to be apportioned or attributed to…

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Zandu Pharmaceuticals Works Ltd. v. CIT (350 ITR 366) — Cited in 68 Judgments | BharatTax