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    <title>2022 (7) TMI 1508 - ITAT MUMBAI</title>
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    <description>Recurring transfer pricing, disallowance, depreciation, inventory valuation, employee incentive expenditure, royalty accrual, and treaty-based tax refund issues were examined in the assessee&#039;s own case. The analysis applies consistency where prior years had accepted the same treatment, requires recorded dissatisfaction before Rule 8D can be invoked, recognises balance additional depreciation in the subsequent year where the first-year claim was constrained by short usage, and treats waived royalty as non-accrued absent an enforceable right to receive it. Matters involving excess dividend distribution tax under a treaty claim and expenditure under section 35(2AB) were sent back for factual verification.</description>
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