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...
Profits from an eligible windmill unit's electricity transferred for captive consumption qualify for deduction under section 80IA. The profit must be computed using the rate charged by the Electricity Board to consumers, rather than the lower rate paid by the Board to generating companies. Payments were not liable to disallowance merely because payees could not be produced after a substantial lapse of time or because expenditure had increased over earlier years. The nature of payees, including labourers, contractors and job workers, and the fact that several payments were below the tax-deduction threshold, precluded treatment of the payments as unexplained. Deduction for captive wind-generated electricity and the payment claims were consequently accepted.
Profits from an eligible windmill unit's electricity transferred for captive consumption qualify for deduction under section 80IA. The profit must be computed using the rate charged by the Electricity Board to consumers, rather than the lower rate paid by the Board to generating companies. Payments were not liable to disallowance merely because payees could not be produced after a substantial lapse of time or because expenditure had increased over earlier years. The nature of payees, including labourers, contractors and job workers, and the fact that several payments were below the tax-deduction threshold, precluded treatment of the payments as unexplained. Deduction for captive wind-generated electricity and the payment claims were consequently accepted.
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