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...
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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