Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded.

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....Export commission paid to a Belgian entity was disallowed for failure to sustain treaty benefit under the Most Favoured Nation clause. Goodwill arising from amalgamation or a slump sale was treated as a depreciable business or commercial right, with the exclusion of goodwill from depreciable intangibles applying prospectively. Infrastructure development charges for long-term leased industrial land were revenue expenditure, and foreign-currency hedging swap charges were independently deductible as bank remuneration rather than adjustments to asset cost. Under section 14A, interest disallowance was unwarranted where own funds exceeded investments, while only exempt-income-yielding investments could be considered for administrative expenditure.........