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...
Depreciation at the higher rate for life-saving medical equipment was denied where the assessee's operation theatre, air pipeline system, anaesthesia trolley system and stabilizer were not specifically listed in the depreciation table and were not remotely identical to the notified equipment. On that basis, allowance of depreciation at 40% was treated as a mistake apparent from the record, and rectification under section 154 was upheld. The Tribunal sustained restriction of depreciation to 15% and rejected reliance on the cited High Court ruling because that case involved equipment found identical to the specified machinery, which was not the position here.
Depreciation at the higher rate for life-saving medical equipment was denied where the assessee's operation theatre, air pipeline system, anaesthesia trolley system and stabilizer were not specifically listed in the depreciation table and were not remotely identical to the notified equipment. On that basis, allowance of depreciation at 40% was treated as a mistake apparent from the record, and rectification under section 154 was upheld. The Tribunal sustained restriction of depreciation to 15% and rejected reliance on the cited High Court ruling because that case involved equipment found identical to the specified machinery, which was not the position here.
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