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    <title>2008 (11) TMI 430 - ITAT MUMBAI</title>
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    <description>Section 14A disallowance was remitted for fresh examination in light of the Special Bench view and the Tribunal&#039;s earlier order in the assessee&#039;s case. On transfer pricing for bare boat charter hire, the CUP comparables were found insufficient for a 22-year-old vessel, but the cost plus approach was accepted to the extent that arm&#039;s length price must be based on direct and indirect costs plus a normal gross profit mark-up, not by reducing the cost base as dividend. The revenue&#039;s objections to depreciation, hire charges, foreign exchange fluctuation depreciation, lease rental, section 33AC deduction, and non-convertible debenture expenditure were rejected, and the first appellate relief was sustained.</description>
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      <title>2008 (11) TMI 430 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=121773</link>
      <description>Section 14A disallowance was remitted for fresh examination in light of the Special Bench view and the Tribunal&#039;s earlier order in the assessee&#039;s case. On transfer pricing for bare boat charter hire, the CUP comparables were found insufficient for a 22-year-old vessel, but the cost plus approach was accepted to the extent that arm&#039;s length price must be based on direct and indirect costs plus a normal gross profit mark-up, not by reducing the cost base as dividend. The revenue&#039;s objections to depreciation, hire charges, foreign exchange fluctuation depreciation, lease rental, section 33AC deduction, and non-convertible debenture expenditure were rejected, and the first appellate relief was sustained.</description>
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      <pubDate>Fri, 21 Nov 2008 00:00:00 +0530</pubDate>
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