Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Depreciation is allowable on acquired rights to use a brand name and on an acquired marketing and distribution network where those rights form part of the opening written-down value of the relevant intangible-asset block. Section 32(1)(ii) covers trade marks, licences, franchises and other business or commercial rights of similar nature, a scope broad enough to include these acquired intangible assets. The treatment of goodwill as a comparable business or commercial right supports this interpretation. The depreciation claim was therefore sustained for the relevant assessment year.
Depreciation is allowable on acquired rights to use a brand name and on an acquired marketing and distribution network where those rights form part of the opening written-down value of the relevant intangible-asset block. Section 32(1)(ii) covers trade marks, licences, franchises and other business or commercial rights of similar nature, a scope broad enough to include these acquired intangible assets. The treatment of goodwill as a comparable business or commercial right supports this interpretation. The depreciation claim was therefore sustained for the relevant assessment year.
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