Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
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.
Note: It is a system-generated summary and is for quick reference only.
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