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 depreciation ETP plant - Merely because a bill submitted by the assessee was bogus or fabricated cannot negate the other evidences such as the inspection carried out after repair of the ETP plant by the officials of the MPCB, carriage of the various parts of the plant through transporters from Delhi to Aurangabad, payments made through banking Channel etc. - depreciation allowable
Disallowance of depreciation ETP plant - Merely because a bill submitted by the assessee was bogus or fabricated cannot negate the other evidences such as the inspection carried out after repair of the ETP plant by the officials of the MPCB, carriage of the various parts of the plant through transporters from Delhi to Aurangabad, payments made through banking Channel etc. - depreciation allowable
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