
Case Law Analysis
|Income Tax Appellate Tribunal
Section 37(1) IT Act | Cost Allocation to Group Companies Permissible with Contractual Agreement & Rational Basis : ITAT Mumbai
ITAT Mumbai rules that inter-company cost allocations under Section 37(1) of the Income Tax Act are deductible if backed by a contractual agreement and a rational allocation method. The ruling clarifies that group companies can claim such expenses without disallowance if they demonstrate a clear business nexus and avoid markup, offering relief to corporate taxpayers.