Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
ITAT adjudicated a tax dispute involving surface rights and intangible asset depreciation claims. The tribunal partially allowed the assessee's appeal, permitting amortization of surface rights based on evidence that the mining rights acquisition did not confer tangible benefits to the transferor entity. Regarding depreciation on equity shares issued free of cost, the tribunal rejected the claim, finding no demonstrable business advantage or documentary proof of technical support. The tribunal sustained lower authorities' orders, dismissing the assessee's claim for depreciation on the purported intangible asset. The decision emphasized the necessity of substantive evidence to support tax deduction claims related to business rights and asset acquisitions.
ITAT adjudicated a tax dispute involving surface rights and intangible asset depreciation claims. The tribunal partially allowed the assessee's appeal, permitting amortization of surface rights based on evidence that the mining rights acquisition did not confer tangible benefits to the transferor entity. Regarding depreciation on equity shares issued free of cost, the tribunal rejected the claim, finding no demonstrable business advantage or documentary proof of technical support. The tribunal sustained lower authorities' orders, dismissing the assessee's claim for depreciation on the purported intangible asset. The decision emphasized the necessity of substantive evidence to support tax deduction claims related to business rights and asset acquisitions.
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