Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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