https://www.taxtmi.com/caselaws?id=461952 The ITAT Mumbai dismissed revenue appeals and allowed assessee's appeal on multiple issues. The AO's disallowance under section 14A r.w. rule 8D was deleted as the AO failed to record satisfaction before invoking provisions, which is a mandatory prerequisite. Depreciation on intangibles representing business contract acquisition was allowed, as the assessee acquired valuable commercial rights qualifying as intangible assets under section 32(1)(ii). The TPO's transfer pricing adjustment was rejected for not following prescribed methods under section 92C(1), with the tribunal noting that proper valuation expertise was required. Notional foreign exchange loss from option contracts was held eligible for deduction under section 10AA as part of export activity profits. en-us Wed, 12 Oct 2022 00:00:00 +0530 Sat, 10 May 2025 23:25:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461952 The ITAT Mumbai dismissed revenue appeals and allowed assessee's appeal on multiple issues. The AO's disallowance under section 14A r.w. rule 8D was deleted as the AO failed to record satisfaction before invoking provisions, which is a mandatory prerequisite. Depreciation on intangibles representing business contract acquisition was allowed, as the assessee acquired valuable commercial rights qualifying as intangible assets under section 32(1)(ii). The TPO's transfer pricing adjustment was rejected for not following prescribed methods under section 92C(1), with the tribunal noting that proper valuation expertise was required. Notional foreign exchange loss from option contracts was held eligible for deduction under section 10AA as part of export activity profits. Case-Laws Income Tax Wed, 12 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461952