Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Depreciation on goodwill was disallowed because the claimed goodwill rested only on a business transfer agreement that was unsigned by the buyer and unregistered, with no other duly executed document produced. The Tribunal applied the principle that an unsigned document lacks legal sanctity and that an unregistered agreement has no enforceable effect in law. It also noted that the seller's proprietor was a designated partner of the assessee LLP, contrary to the claim of no relationship between the parties. On that basis, the alleged goodwill had no value in law and the disallowance was sustained.
Depreciation on goodwill was disallowed because the claimed goodwill rested only on a business transfer agreement that was unsigned by the buyer and unregistered, with no other duly executed document produced. The Tribunal applied the principle that an unsigned document lacks legal sanctity and that an unregistered agreement has no enforceable effect in law. It also noted that the seller's proprietor was a designated partner of the assessee LLP, contrary to the claim of no relationship between the parties. On that basis, the alleged goodwill had no value in law and the disallowance was sustained.
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