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    <title>2011 (2) TMI 68 - ITAT, MUMBAI</title>
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    <description>WHO certification charges incurred to secure recognition of manufacturing facilities and vaccine quality for overseas and UN supply were treated as capital expenditure because they conferred an enduring benefit, so the disallowance was sustained. Transfer pricing adjustment for export of vaccines and royalty required reconsideration because the comparables and margin comparison were not shown to satisfy the transactional net margin method; the matter was remanded for fresh adjudication, while the necessity of royalty payment under the arrangement was upheld. Higher depreciation on motor cars as commercial vehicles also depended on the applicable depreciation schedule and Motor Vehicles Act definition, and the issue was remanded for verification.</description>
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    <pubDate>Fri, 25 Feb 2011 00:00:00 +0530</pubDate>
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      <title>2011 (2) TMI 68 - ITAT, MUMBAI</title>
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      <description>WHO certification charges incurred to secure recognition of manufacturing facilities and vaccine quality for overseas and UN supply were treated as capital expenditure because they conferred an enduring benefit, so the disallowance was sustained. Transfer pricing adjustment for export of vaccines and royalty required reconsideration because the comparables and margin comparison were not shown to satisfy the transactional net margin method; the matter was remanded for fresh adjudication, while the necessity of royalty payment under the arrangement was upheld. Higher depreciation on motor cars as commercial vehicles also depended on the applicable depreciation schedule and Motor Vehicles Act definition, and the issue was remanded for verification.</description>
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