Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
Depreciation on goodwill arising from amalgamation was held allowable for assessment years prior to the Finance Act, 2021 amendment excluding goodwill from depreciable assets. Applying the settled principle in SMIFS Securities Ltd., the ITAT found that goodwill remained an intangible asset eligible for depreciation for the relevant pre-amendment years, so the Assessing Officer was not justified in disallowing the claim. The Tribunal upheld the Commissioner (Appeals)' deletion of the disallowance and rejected the Revenue's objections based on the consideration, valuation, and amalgamation scheme.
Depreciation on goodwill arising from amalgamation was held allowable for assessment years prior to the Finance Act, 2021 amendment excluding goodwill from depreciable assets. Applying the settled principle in SMIFS Securities Ltd., the ITAT found that goodwill remained an intangible asset eligible for depreciation for the relevant pre-amendment years, so the Assessing Officer was not justified in disallowing the claim. The Tribunal upheld the Commissioner (Appeals)' deletion of the disallowance and rejected the Revenue's objections based on the consideration, valuation, and amalgamation scheme.
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