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...
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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