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 depreciation in respect of asset given on lease - the lessee has been given only right to use the asset for the terms of the lease on payment of specified lease rent for a lease period of 10 years - the assessee is entitled for depreciation on the leased asset as per provisions of section 32(1) - CIT(A) after considering relevant facts has rightly deleted additions made by the AO towards disallowance of depreciation - AT
Disallowance of depreciation in respect of asset given on lease - the lessee has been given only right to use the asset for the terms of the lease on payment of specified lease rent for a lease period of 10 years - the assessee is entitled for depreciation on the leased asset as per provisions of section 32(1) - CIT(A) after considering relevant facts has rightly deleted additions made by the AO towards disallowance of depreciation - AT
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