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of ITAT upheld the disallowance of a claimed 'depreciation' recharge for occupancy expenses, finding the taxpayer neither owned nor expended on the leasehold asset and holding such recharges non-deductible under s.32/s.37(1). The Tribunal deleted the addition relating to RSU/ESOP expenditure. An intimation addition concerning leave encashment/bonus was remitted for AO action on the pending s.154 rectification. CCDs issued to associated enterprises were held to be debt until conversion; interest thereon is prima facie allowable and transfer-pricing treatment was restored to the TPO/AO for de novo benchmarking and ALP determination (section 94B contentions kept open). TDS credit and s.234A/234B interest issues were remitted to the AO for verification and consequential action in accordance with law.
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