Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Depreciation on goodwill arising from amalgamation remained allowable because the claim had consistently been accepted in the taxpayer's earlier assessment years and no material factual change was shown. The Revenue's reliance on a decision involving artificial and colourable creation of goodwill was distinguishable, with no comparable finding here. Deduction of employee stock option reimbursement expenditure was also sustained, as an earlier Tribunal ruling in the taxpayer's own matter had addressed objections on business purpose, capital character and tax deduction at source, and no distinguishing facts were produced. The Revenue's appeal was dismissed.
Depreciation on goodwill arising from amalgamation remained allowable because the claim had consistently been accepted in the taxpayer's earlier assessment years and no material factual change was shown. The Revenue's reliance on a decision involving artificial and colourable creation of goodwill was distinguishable, with no comparable finding here. Deduction of employee stock option reimbursement expenditure was also sustained, as an earlier Tribunal ruling in the taxpayer's own matter had addressed objections on business purpose, capital character and tax deduction at source, and no distinguishing facts were produced. The Revenue's appeal was dismissed.
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