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...
Depreciation on right to collect toll tax on road developed by the Assessee - The Tribunal recognized the right to collect toll on roads developed by the appellant as a commercial right, an intangible asset under Section 32(1)(ii) of the Act. - Accordingly, AO directed to grant depreciation on the toll collection right as an intangible asset and to adjust the deduction under Section 80IA(4) based on this allowance.
Depreciation on right to collect toll tax on road developed by the Assessee - The Tribunal recognized the right to collect toll on roads developed by the appellant as a commercial right, an intangible asset under Section 32(1)(ii) of the Act. - Accordingly, AO directed to grant depreciation on the toll collection right as an intangible asset and to adjust the deduction under Section 80IA(4) based on this allowance.
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