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...
Deduction u/s 80IA(4) on wind mills and solar power plants - Whether each windmill and solar power plant installed by the assessee should be considered as separate undertakings or one undertaking? - The Tribunal, referencing its own previous decisions and the lack of any new material facts or judicial precedents, upheld the Commissioner of Income Tax (Appeals)'s ruling. It was concluded that each windmill and solar power plant must be treated as separate undertakings for the calculation of deductions under section 80IA(4), thereby dismissing the Revenue's appeal on this ground. - Furthermore, on Applicability of Notional Brought Forward Losses and Depreciation, the Tribunal followed the principles laid down by the High Courts, which stated that losses from eligible businesses, once set off against other income, cannot be notionally carried forward to reduce the profits of the eligible business in subsequent years for the purpose of computing deduction under section 80IA.
Deduction u/s 80IA(4) on wind mills and solar power plants - Whether each windmill and solar power plant installed by the assessee should be considered as separate undertakings or one undertaking? - The Tribunal, referencing its own previous decisions and the lack of any new material facts or judicial precedents, upheld the Commissioner of Income Tax (Appeals)'s ruling. It was concluded that each windmill and solar power plant must be treated as separate undertakings for the calculation of deductions under section 80IA(4), thereby dismissing the Revenue's appeal on this ground. - Furthermore, on Applicability of Notional Brought Forward Losses and Depreciation, the Tribunal followed the principles laid down by the High Courts, which stated that losses from eligible businesses, once set off against other income, cannot be notionally carried forward to reduce the profits of the eligible business in subsequent years for the purpose of computing deduction under section 80IA.
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