Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Rectification of mistake u/s 254 - Depreciation on the non-compete fee denied - CIT(A) allowed the claim - ITAT rejected the claim - Whether AO has accepted the claim of the assessee - the words “similar business or commercial rights” have to necessarily result in an intangible asset against the entire world which can be asserted as such to qualify for depreciation under Section 32(1)(ii) - Merely because another appeal raising similar questions has been admitted by this Court, also does not persuade us to admit the present appeal as well only on this ground. - HC
Rectification of mistake u/s 254 - Depreciation on the non-compete fee denied - CIT(A) allowed the claim - ITAT rejected the claim - Whether AO has accepted the claim of the assessee - the words “similar business or commercial rights” have to necessarily result in an intangible asset against the entire world which can be asserted as such to qualify for depreciation under Section 32(1)(ii) - Merely because another appeal raising similar questions has been admitted by this Court, also does not persuade us to admit the present appeal as well only on this ground. - HC
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