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...
Reducing the subsidy for the purpose of calculation of depreciation - When the statute does not contemplate computation of actual cost of assets after it becomes part of a block of assets, Explanation 10 to Subsection (1) of Section 43 of the Act cannot be made applicable to assets of which the actual cost has been determined and forms part of a block of assets. - AT
Reducing the subsidy for the purpose of calculation of depreciation - When the statute does not contemplate computation of actual cost of assets after it becomes part of a block of assets, Explanation 10 to Subsection (1) of Section 43 of the Act cannot be made applicable to assets of which the actual cost has been determined and forms part of a block of assets. - AT
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