Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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