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...
Nature of expenses - repair and maintenance - revenue or capital expenditure - current repair u/s 30 - treatment of expenses incurred on renovation and refurbishment of Hotel - Tribunal was wrongly burdened by the fact that the renovation, refurbishment and repairs were carried out over several years and that the total amount incurred was Rs. 35 crores, which was much more than the cost at which the hotel had been constructed. - Claim allowed as revenue expenditure - HC
Nature of expenses - repair and maintenance - revenue or capital expenditure - current repair u/s 30 - treatment of expenses incurred on renovation and refurbishment of Hotel - Tribunal was wrongly burdened by the fact that the renovation, refurbishment and repairs were carried out over several years and that the total amount incurred was Rs. 35 crores, which was much more than the cost at which the hotel had been constructed. - Claim allowed as revenue expenditure - HC
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