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...
Section 11(6) bars depreciation as application of income for charitable purposes only where the acquisition cost of the relevant asset has already been claimed as application of income in the same or an earlier year. Where a charitable institution has not claimed capital expenditure on acquiring fixed assets as revenue application and claims only depreciation, the restriction does not create a double deduction. Depreciation on those fixed assets may therefore be treated as allowable application of income for the relevant assessment year.
Section 11(6) bars depreciation as application of income for charitable purposes only where the acquisition cost of the relevant asset has already been claimed as application of income in the same or an earlier year. Where a charitable institution has not claimed capital expenditure on acquiring fixed assets as revenue application and claims only depreciation, the restriction does not create a double deduction. Depreciation on those fixed assets may therefore be treated as allowable application of income for the relevant assessment year.
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