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...
Depreciation - Determination of WDV - Cost of Acquisition - waiver or write of loan - the manner of repayment of loan cannot affect the cost of asset. The actual cost must depend on the amount paid by the assessee to acquire the cost. The amount may have been borrowed by the assessee but even if the assessee did not repay the loan, it will not alter the cost of asset. - AO is not justified to reduce WDV of assets to Rs. Nil and thereby disallow any part of depreciation - AT
Depreciation - Determination of WDV - Cost of Acquisition - waiver or write of loan - the manner of repayment of loan cannot affect the cost of asset. The actual cost must depend on the amount paid by the assessee to acquire the cost. The amount may have been borrowed by the assessee but even if the assessee did not repay the loan, it will not alter the cost of asset. - AO is not justified to reduce WDV of assets to Rs. Nil and thereby disallow any part of depreciation - AT
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