Section 80IC Deduction Allowed: ITAT Delhi Rejects Sham Amalgamation Claim

DCIT Vs Mahle Filters Systems (India) Ltd (ITAT Delhi) 80IC Deduction Protected: ITAT Delhi Rejects “Sham Amalgamation” Theory, Allows Expense Allocation on After-Market Sales Basis  Delhi ITAT  disposed of cross-appeals arising from a large Section 80IC deduction dispute post-amalgamation. The Tribunal upheld the CIT(A)’s order granting substantial relief to the assessee and dismissed the Revenue’s appeal in entirety, while partly allowing the assessee’s appeal. On the core issue, the ITAT held that after-market (trading) expenses were correctly allocable on the basis of after-mar...