Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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