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 software expenses - Disallowance is in respect of expenditure claimed towards “repairs - computers-annual maintenance” and “Repairs-computers-others” - AO has treated it as capital expenditure on the reasoning that it was towards purchase of licenses and allowed depreciation at the rate of 25% - even if the expenditure is treated as capital, depreciation would be allowable at the rate of 60%
Disallowance of software expenses - Disallowance is in respect of expenditure claimed towards “repairs - computers-annual maintenance” and “Repairs-computers-others” - AO has treated it as capital expenditure on the reasoning that it was towards purchase of licenses and allowed depreciation at the rate of 25% - even if the expenditure is treated as capital, depreciation would be allowable at the rate of 60%
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