Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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