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 claimed on Automated Teller Machines (ATM) - @ 15% OR 60% - the test would be: Does an ATM fulfil the functions of a Computer in the business activity of an assessee? Is it a tool of his trade with which it carries on his business? - AO directed to allow depreciation @60% - AT
Disallowance of depreciation claimed on Automated Teller Machines (ATM) - @ 15% OR 60% - the test would be: Does an ATM fulfil the functions of a Computer in the business activity of an assessee? Is it a tool of his trade with which it carries on his business? - AO directed to allow depreciation @60% - AT
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