Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Depreciation on goodwill - amalgamation - acquisition of the deferred sales tax liabilities - MOU agreed to purchase the Assets consisting the Immovable properties - On the date of execution of MoUs, the liability was a known liability, therefore, it cannot be treated that it is a intangible asset and cannot be treated as a goodwill. Before us the assessee has not produced any details in regard to how he has arrived the value of assets and entry in the books of accounts. Therefore the contention of the assessee is rejected - AT
Depreciation on goodwill - amalgamation - acquisition of the deferred sales tax liabilities - MOU agreed to purchase the Assets consisting the Immovable properties - On the date of execution of MoUs, the liability was a known liability, therefore, it cannot be treated that it is a intangible asset and cannot be treated as a goodwill. Before us the assessee has not produced any details in regard to how he has arrived the value of assets and entry in the books of accounts. Therefore the contention of the assessee is rejected - AT
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