Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
Goodwill arising from acquisition of a going-concern business under a slump-sale agreement may constitute a depreciable intangible asset where assumed liabilities exceed acquired assets and are subsequently discharged. Such excess liabilities represent economic consideration for business and commercial rights, notwithstanding the absence of separately stated consideration or individual asset valuations. The Finance Act, 2021 exclusion of goodwill from depreciable intangible assets operates prospectively. Where depreciation on goodwill is allowable under normal provisions, no consequential add-back is warranted in book-profit computation. TDS credit is available in the year in which corresponding income is assessable, subject to verification that the income was offered to tax in that year.
Goodwill arising from acquisition of a going-concern business under a slump-sale agreement may constitute a depreciable intangible asset where assumed liabilities exceed acquired assets and are subsequently discharged. Such excess liabilities represent economic consideration for business and commercial rights, notwithstanding the absence of separately stated consideration or individual asset valuations. The Finance Act, 2021 exclusion of goodwill from depreciable intangible assets operates prospectively. Where depreciation on goodwill is allowable under normal provisions, no consequential add-back is warranted in book-profit computation. TDS credit is available in the year in which corresponding income is assessable, subject to verification that the income was offered to tax in that year.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
