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...
The High Court held that the solar plant was put to use for the purpose of business on 20.03.2013 when it started generating electricity, despite being non-functional initially due to defects. Consequently, the assessee was entitled to claim depreciation on the solar plant from the financial year 2012-13 itself, even though synchronization with the grid took place on 20.04.2013 in the subsequent financial year 2013-14. The appeal filed by the Revenue was dismissed.
The High Court held that the solar plant was put to use for the purpose of business on 20.03.2013 when it started generating electricity, despite being non-functional initially due to defects. Consequently, the assessee was entitled to claim depreciation on the solar plant from the financial year 2012-13 itself, even though synchronization with the grid took place on 20.04.2013 in the subsequent financial year 2013-14. The appeal filed by the Revenue was dismissed.
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