Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Recurring annual maintenance charges for optical fibre network usage were treated as revenue expenditure, while upfront connectivity fees were to be amortised on a straight-line basis over the relevant 15-year contractual term, subject to agreement-wise verification. For exempt-income disallowance, own funds in excess of investments and use of borrowed funds for business supported denial of interest disallowance; administrative disallowance was confined to investments yielding exempt income and capped by exempt income earned. The text also notes that broadband network acquisition rights, goodwill arising on amalgamation, and non-compete fee can qualify as depreciable intangible assets, and that appellate authorities may entertain additional claims when facts are already on record.
Recurring annual maintenance charges for optical fibre network usage were treated as revenue expenditure, while upfront connectivity fees were to be amortised on a straight-line basis over the relevant 15-year contractual term, subject to agreement-wise verification. For exempt-income disallowance, own funds in excess of investments and use of borrowed funds for business supported denial of interest disallowance; administrative disallowance was confined to investments yielding exempt income and capped by exempt income earned. The text also notes that broadband network acquisition rights, goodwill arising on amalgamation, and non-compete fee can qualify as depreciable intangible assets, and that appellate authorities may entertain additional claims when facts are already on record.
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