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...
Disallowance of additional depreciation - use of machinery in the actual process of manufacture of food products/sweets/namkeens - items of the assets installed at retail outlets(sweet shops) - retail outlets are not either office promises or residential accommodation in the nature of the guesthouse excluded u/s 32(1)(iia) for the additional depreciation - claim allowed.
Disallowance of additional depreciation - use of machinery in the actual process of manufacture of food products/sweets/namkeens - items of the assets installed at retail outlets(sweet shops) - retail outlets are not either office promises or residential accommodation in the nature of the guesthouse excluded u/s 32(1)(iia) for the additional depreciation - claim allowed.
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