Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
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Penalty u/s 271(1)(c) was imposed for disallowance of depreciation on non-compete fees. The CIT(A) relied on Sharp Business System [2012 (11) TMI 324 - Delhi High Court], which is under challenge before the Supreme Court. Pepsico India Holding Pvt. Ltd. [2024 (4) TMI 1154 - Delhi High Court] allowed depreciation on non-compete fees after considering Sharp Business System. Different High Courts have divergent views on allowability of depreciation on non-compete fees, and the matter is pending before the Supreme Court. Considering the contentious issue, provisions of Section 271(1)(c) cannot be attracted. Assessee's appeal allowed.
Penalty u/s 271(1)(c) was imposed for disallowance of depreciation on non-compete fees. The CIT(A) relied on Sharp Business System [2012 (11) TMI 324 - Delhi High Court], which is under challenge before the Supreme Court. Pepsico India Holding Pvt. Ltd. [2024 (4) TMI 1154 - Delhi High Court] allowed depreciation on non-compete fees after considering Sharp Business System. Different High Courts have divergent views on allowability of depreciation on non-compete fees, and the matter is pending before the Supreme Court. Considering the contentious issue, provisions of Section 271(1)(c) cannot be attracted. Assessee's appeal allowed.
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