Internal TNMM and consistency drive transfer pricing relief, while replacement spares fail for additional depreciation.

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....Internal TNMM was upheld for sale of finished goods to associated enterprises because earlier years had accepted that method, CUP was not reliably workable, and no material change or distinguishing feature was shown; the transfer pricing adjustment was deleted for both years. The adjustment for sales promotion and marketing services from associated enterprises was also deleted on the same consistency basis. Additional depreciation on replacement spares was denied because it did not create new plant and machinery, while prior period expenses were not addable to book profit; interest capitalisation to capital work in progress failed for lack of nexus, and the weighted deduction for in-house research and development was allowed without DSIR quantification for the years in question. Additional depreciation on new tanks was allowed.....