Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Depreciation claimed by the appellant - goodwill acquired under slump sale - The tribunal noted that, The amendment brought in by the Finance Act 2021 and the Memorandum explaining the provisions of the Bill makes it explicitly clear that, the amendment was prospective. - Regarding valuation, ITAT observed that, we come to the reasonablness of the valuation exercise of the goodwill at Rs. 160 crores, it is indeed true that since the transaction was with a related party, the fair market valuation ought to be examined; but at the same time, on the specific facts of this case, it is necessary to also take cognizance of the material information that the excess consideration (towards goodwill) paid by the appellant to VEGL was offerred by the latter as taxable capital gains in its hands. - AO directed to allow the claim of depreciation.
Depreciation claimed by the appellant - goodwill acquired under slump sale - The tribunal noted that, The amendment brought in by the Finance Act 2021 and the Memorandum explaining the provisions of the Bill makes it explicitly clear that, the amendment was prospective. - Regarding valuation, ITAT observed that, we come to the reasonablness of the valuation exercise of the goodwill at Rs. 160 crores, it is indeed true that since the transaction was with a related party, the fair market valuation ought to be examined; but at the same time, on the specific facts of this case, it is necessary to also take cognizance of the material information that the excess consideration (towards goodwill) paid by the appellant to VEGL was offerred by the latter as taxable capital gains in its hands. - AO directed to allow the claim of depreciation.
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TaxTMI 
TaxTMI 
of 4918 
