Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The assessee, after being amalgamated with another company, treated the excess consideration paid over the net assets acquired as goodwill and claimed depreciation at 25% on the written-down value. The tax authorities disallowed the claim. However, the Tribunal observed that the assessee had consistently claimed depreciation on goodwill since FY 2006-07, and the Revenue's appeals on this issue for previous years were dismissed by the Tribunal. Following its earlier decisions and a recent Kolkata Tribunal ruling in a similar case, the Tribunal decided the appeal in favor of the assessee, allowing the depreciation claim on goodwill.
The assessee, after being amalgamated with another company, treated the excess consideration paid over the net assets acquired as goodwill and claimed depreciation at 25% on the written-down value. The tax authorities disallowed the claim. However, the Tribunal observed that the assessee had consistently claimed depreciation on goodwill since FY 2006-07, and the Revenue's appeals on this issue for previous years were dismissed by the Tribunal. Following its earlier decisions and a recent Kolkata Tribunal ruling in a similar case, the Tribunal decided the appeal in favor of the assessee, allowing the depreciation claim on goodwill.
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