Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Disallowance of depreciation u/s 32 - intangible assets - amount paid for non compete fees - non compete fee is not an eligible intangible asset as the words “similar business or commercial rights” have to necessary result in an intangible asset against the entire word which can be asserted as such to qualify for depreciation u/s 32(1)(ii) of the Act which non compete fees lacks. - AT
Disallowance of depreciation u/s 32 - intangible assets - amount paid for non compete fees - non compete fee is not an eligible intangible asset as the words “similar business or commercial rights” have to necessary result in an intangible asset against the entire word which can be asserted as such to qualify for depreciation u/s 32(1)(ii) of the Act which non compete fees lacks. - AT
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