Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Transfer pricing of intra-group services required fresh examination because CUP could not be applied at nil without uncontrolled comparable transactions, and the TPO had to consider the evidence and additional evidence on actual receipt and nature of services; the impugned adjustment was therefore set aside and remanded. On unabsorbed depreciation, the Tribunal held that depreciation relating to earlier years, not absorbed by financial year 2002-03, merged with subsequent-year depreciation and was not subject to the earlier eight-year restriction after the amendment to section 32(2); the assessee's claim for carry forward and set-off beyond eight years was allowed and the Revenue's challenge was rejected.
Transfer pricing of intra-group services required fresh examination because CUP could not be applied at nil without uncontrolled comparable transactions, and the TPO had to consider the evidence and additional evidence on actual receipt and nature of services; the impugned adjustment was therefore set aside and remanded. On unabsorbed depreciation, the Tribunal held that depreciation relating to earlier years, not absorbed by financial year 2002-03, merged with subsequent-year depreciation and was not subject to the earlier eight-year restriction after the amendment to section 32(2); the assessee's claim for carry forward and set-off beyond eight years was allowed and the Revenue's challenge was rejected.
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