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ITAT upholds the CIT(A)'s rejection of Revenue's transfer pricing adjustments, finding the assessee to be a captive manufacturer and dismissing Revenue's appeals on gross margin and management support service additions; those orders stand. ITAT remits the disputed additional depreciation claim to the AO for recalculation and allowance of the correct amount, permitting the assessee to submit supporting particulars and be heard. The AO is directed to verify and recompute the section 14A/Rule 8D disallowance. Drawings used in motorcycle design are held to qualify as "plant" for section 32AC, and the section 32AC deduction is allowed; claims for additional depreciation under section 32(1)(iia) are admitted and remitted to the AO for fresh, reasoned adjudication.
ITAT upholds the CIT(A)'s rejection of Revenue's transfer pricing adjustments, finding the assessee to be a captive manufacturer and dismissing Revenue's appeals on gross margin and management support service additions; those orders stand. ITAT remits the disputed additional depreciation claim to the AO for recalculation and allowance of the correct amount, permitting the assessee to submit supporting particulars and be heard. The AO is directed to verify and recompute the section 14A/Rule 8D disallowance. Drawings used in motorcycle design are held to qualify as "plant" for section 32AC, and the section 32AC deduction is allowed; claims for additional depreciation under section 32(1)(iia) are admitted and remitted to the AO for fresh, reasoned adjudication.
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