Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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