Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Interest paid for delayed licence or migration fee for radio channels was treated as revenue expenditure because the stations were already operational and the payment was compensatory, not for creating a new asset. A section 14A disallowance was deleted because no exempt income was earned from the relevant investments. CSR donation paid to an approved section 80G fund was held deductible, as CSR disallowance under section 37(1) did not bar the claim and any ambiguity in the taxing provision had to be resolved in favour of the assessee. Depreciation was allowed on workforce-related intangible rights acquired under a slump sale, as the employees formed part of the going concern and the amalgamation proviso was inapplicable.
Interest paid for delayed licence or migration fee for radio channels was treated as revenue expenditure because the stations were already operational and the payment was compensatory, not for creating a new asset. A section 14A disallowance was deleted because no exempt income was earned from the relevant investments. CSR donation paid to an approved section 80G fund was held deductible, as CSR disallowance under section 37(1) did not bar the claim and any ambiguity in the taxing provision had to be resolved in favour of the assessee. Depreciation was allowed on workforce-related intangible rights acquired under a slump sale, as the employees formed part of the going concern and the amalgamation proviso was inapplicable.
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