Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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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