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    <title>2016 (7) TMI 1245 - BOMBAY HIGH COURT</title>
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    <description>Transfer pricing adjustments were confined to associated enterprise transactions, concluding against revenue and for the assessee. Allowable deduction under deduction provisions for specified units requires nexus of research and interest expenses to the claiming unit, with the Tribunals reliance on precedent upheld and no substantial question of law. Expenditure on termination of contracts was treated as commercially expedient and eligible as a business deduction, a possible view sustained. Unabsorbed depreciation from intervening assessment years prior to the amendment was permitted to be set off as carried forward depreciation in later years, following prior authority and CBDT Circular guidance. Appeal admitted on a tax withholding disallowance point.</description>
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      <description>Transfer pricing adjustments were confined to associated enterprise transactions, concluding against revenue and for the assessee. Allowable deduction under deduction provisions for specified units requires nexus of research and interest expenses to the claiming unit, with the Tribunals reliance on precedent upheld and no substantial question of law. Expenditure on termination of contracts was treated as commercially expedient and eligible as a business deduction, a possible view sustained. Unabsorbed depreciation from intervening assessment years prior to the amendment was permitted to be set off as carried forward depreciation in later years, following prior authority and CBDT Circular guidance. Appeal admitted on a tax withholding disallowance point.</description>
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