Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Disallowance of depreciation on lease hold land claimed u/s 32(1)(ii) - “right to mine” and the “surface right” falls within the definition of intangible assets as defined in Section 32(1)(ii) and Explanation 3 to Section 32(1(ii) - AO directed to treat this as “Capital Expenditure”, which is in enduring nature and grant applicable rate of depreciation on it as appliable to commercial rights of similar nature. - AT
Disallowance of depreciation on lease hold land claimed u/s 32(1)(ii) - “right to mine” and the “surface right” falls within the definition of intangible assets as defined in Section 32(1)(ii) and Explanation 3 to Section 32(1(ii) - AO directed to treat this as “Capital Expenditure”, which is in enduring nature and grant applicable rate of depreciation on it as appliable to commercial rights of similar nature. - AT
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