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...
Offshore unit in Dubai treated as proprietary concern, profits taxable in assessee's hands. AO's addition disallowed based on ITAT's consistent rulings favoring assessee. Excess depreciation on furniture and fittings disallowed by AO, CIT(A) directed deletion following ITAT's earlier decisions favoring assessee. Depreciation on goodwill generated on amalgamation disallowed by AO, CIT(A) upheld without examining assessee's contentions. Assessee relied on Urmin Marketing case, where ITAT allowed depreciation on goodwill arising from amalgamation, as provisions cited by AO apply to transferred assets, not goodwill generated. ITAT allowed assessee's claim for depreciation on goodwill, following Supreme Court's Smifs Securities ruling, as goodwill was acquired under amalgamation scheme approved by High Court after tax department's no-objection.
Offshore unit in Dubai treated as proprietary concern, profits taxable in assessee's hands. AO's addition disallowed based on ITAT's consistent rulings favoring assessee. Excess depreciation on furniture and fittings disallowed by AO, CIT(A) directed deletion following ITAT's earlier decisions favoring assessee. Depreciation on goodwill generated on amalgamation disallowed by AO, CIT(A) upheld without examining assessee's contentions. Assessee relied on Urmin Marketing case, where ITAT allowed depreciation on goodwill arising from amalgamation, as provisions cited by AO apply to transferred assets, not goodwill generated. ITAT allowed assessee's claim for depreciation on goodwill, following Supreme Court's Smifs Securities ruling, as goodwill was acquired under amalgamation scheme approved by High Court after tax department's no-objection.
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