Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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