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...
Higher depreciation claim - Receipt from business of hiring of plant and machinery - The assessee’s claim is that since the substantial income i.e. 2/3rd of its income is from hiring business, it qualifies for higher depreciation @ 30%. - Claim allowed - AT
Higher depreciation claim - Receipt from business of hiring of plant and machinery - The assessee’s claim is that since the substantial income i.e. 2/3rd of its income is from hiring business, it qualifies for higher depreciation @ 30%. - Claim allowed - AT
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