S. 80IC : Special category States-Software development-Non-eligible unit-R&D Center-Apportionment of cost-Matter remanded-Deduction under S. 80IC has to be restricted only to the transfer of CD writing activity of the Parwanoo unit to the Pune unit and not beyond that-Entire disallowance made by the AO in respect of sales made to third parties cannot be upheld-Partial disallowance affirmed while computing the Arm’s length Price. [S. 80IA(8), 80IA(10), 80IC, 92C, 92CA(4)]
Biz Secure Labs (P) Ltd. v. Dy. CIT (2022) 220 TTJ 1028 (Pune)(Trib)