Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Claim of depreciation - capitalisation being pre-commencement rent and other expenditure incurred - Section 32 of the Act allows depreciation on actual cost of the asset, which means the actual cost to the assessee. This cost should be construed in ordinarily commercial manner. AS-10 regarding "accounting for fixed assets" issued by the ICAI specifies the components of cost of a fixed asset. - the expenses incurred by the assessee are required to be capitalised - Claim allowed - AT
Claim of depreciation - capitalisation being pre-commencement rent and other expenditure incurred - Section 32 of the Act allows depreciation on actual cost of the asset, which means the actual cost to the assessee. This cost should be construed in ordinarily commercial manner. AS-10 regarding "accounting for fixed assets" issued by the ICAI specifies the components of cost of a fixed asset. - the expenses incurred by the assessee are required to be capitalised - Claim allowed - AT
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