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...
Disallowance of depreciation claimed on the “Goodwill” - The Tribunal reiterated its earlier decision and held that the assessee was entitled to claim depreciation on "Goodwill" arising from the amalgamation, following the precedent set in its own case. Since the year under consideration was the second year of the claim for depreciation on "Goodwill," it was deemed academic to determine eligibility, as depreciation was to be calculated on the opening Written Down Value (WDV) of the asset.
Disallowance of depreciation claimed on the “Goodwill” - The Tribunal reiterated its earlier decision and held that the assessee was entitled to claim depreciation on "Goodwill" arising from the amalgamation, following the precedent set in its own case. Since the year under consideration was the second year of the claim for depreciation on "Goodwill," it was deemed academic to determine eligibility, as depreciation was to be calculated on the opening Written Down Value (WDV) of the asset.
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