Tribunal held that, where the facts and circumstances suggest that the provision of interest free funds to the assesse claiming deduction u/s. 10B was bonafide, artificially imputing non-existent interest costs and denying deduction to the assessee was not warranted. AO was directed to exclude the interest cost imputed for the purpose of determination of profits of the assesse u/s. 10B of the Act . (AY. 2008-09, 2011-12)
Nabros Pharma Ltd. v. ACIT (2018) 68 ITR 6 (SN) (Ahd.) (Trib.)
S. 10B : Export oriented undertakings–Interest free funds- Artificially imputing non-existent interest costs and denying deduction to the assessee was held to be not justified. [S.10B(7), 80IA(10)]