Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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