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    <title>2022 (12) TMI 860 - ITAT KOLKATA</title>
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    <description>ITAT KOLKATA - AT held that CPM was the most appropriate MAM for the assessee&#039;s contract-manufacturing transactions and that the transfer prices were at ALP, dismissing the revenue&#039;s appeal on TP issues. On additional depreciation under s.32(1)(iia) the bench followed precedent and allowed the remaining 50% depreciation to be claimed in a subsequent year where assets were in use for less than 180 days. On foreign exchange loss, the AO&#039;s denial of immediate deduction was restored but the assessee was directed to capitalize the loss and claim depreciation thereon at the applicable rate.</description>
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      <link>https://www.taxtmi.com/caselaws?id=431743</link>
      <description>ITAT KOLKATA - AT held that CPM was the most appropriate MAM for the assessee&#039;s contract-manufacturing transactions and that the transfer prices were at ALP, dismissing the revenue&#039;s appeal on TP issues. On additional depreciation under s.32(1)(iia) the bench followed precedent and allowed the remaining 50% depreciation to be claimed in a subsequent year where assets were in use for less than 180 days. On foreign exchange loss, the AO&#039;s denial of immediate deduction was restored but the assessee was directed to capitalize the loss and claim depreciation thereon at the applicable rate.</description>
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