https://www.taxtmi.com/caselaws?id=256535 For AY 2005-06, the appeal challenging the exclusion of depreciation on the building from operating expenses for transfer pricing adjustment was dismissed. The reassessment order was affirmed, stating that new claims for deductions cannot be made in reassessment proceedings unless directly related to the escaped income being reassessed. For AY 2006-07, the appeal on notional interest was remitted for fresh adjudication, and the transfer pricing adjustment partially allowed, directing exclusion of Canadian branch transactions from ALP computation. The idle capacity adjustment claim was rejected, emphasizing adherence to statutory provisions and consistency with prior rulings. en-us Tue, 03 Feb 2015 00:00:00 +0530 Sat, 14 Feb 2015 22:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=256535 For AY 2005-06, the appeal challenging the exclusion of depreciation on the building from operating expenses for transfer pricing adjustment was dismissed. The reassessment order was affirmed, stating that new claims for deductions cannot be made in reassessment proceedings unless directly related to the escaped income being reassessed. For AY 2006-07, the appeal on notional interest was remitted for fresh adjudication, and the transfer pricing adjustment partially allowed, directing exclusion of Canadian branch transactions from ALP computation. The idle capacity adjustment claim was rejected, emphasizing adherence to statutory provisions and consistency with prior rulings. Case-Laws Income Tax Tue, 03 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=256535