Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Depreciation on goodwill - Business acquired in amalgamation - The ITAT held that, the excess consideration discharged over the net assets, representing goodwill, is eligible for depreciation under Section 32 of the Income Tax Act. The Tribunal found that the scheme of amalgamation was not a device for tax evasion, emphasizing that when a scheme is sanctioned by the court, it is deemed to be in public interest and not opposed to it. The ITAT directed the AO to allow the claim of depreciation on goodwill for the assessment years 2016-17 to 2018-19
Depreciation on goodwill - Business acquired in amalgamation - The ITAT held that, the excess consideration discharged over the net assets, representing goodwill, is eligible for depreciation under Section 32 of the Income Tax Act. The Tribunal found that the scheme of amalgamation was not a device for tax evasion, emphasizing that when a scheme is sanctioned by the court, it is deemed to be in public interest and not opposed to it. The ITAT directed the AO to allow the claim of depreciation on goodwill for the assessment years 2016-17 to 2018-19
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