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...
Goodwill arising from amalgamation of a running business was treated as a depreciable intangible asset because it represented commercial rights covered by the depreciation provision, and the Tribunal followed its earlier years' view in the absence of any change in facts or law. The deletion of disallowance of depreciation on goodwill was upheld. For captive power transfers, the Tribunal accepted the internal CUP benchmark based on the consumer tariff charged by the distribution company for valuing inter-unit electricity sales, holding that regulatory tariff was not the proper market benchmark. On that basis, the transfer pricing adjustment affecting the section 80IA deduction was deleted and the assessee's claim was sustained.
Goodwill arising from amalgamation of a running business was treated as a depreciable intangible asset because it represented commercial rights covered by the depreciation provision, and the Tribunal followed its earlier years' view in the absence of any change in facts or law. The deletion of disallowance of depreciation on goodwill was upheld. For captive power transfers, the Tribunal accepted the internal CUP benchmark based on the consumer tariff charged by the distribution company for valuing inter-unit electricity sales, holding that regulatory tariff was not the proper market benchmark. On that basis, the transfer pricing adjustment affecting the section 80IA deduction was deleted and the assessee's claim was sustained.
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