Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The ITAT ruled in favor of the assessee regarding depreciation claimed on goodwill acquired through amalgamation. The Tribunal found that neither the AO nor CIT(A) had questioned the valuation of goodwill created pursuant to the amalgamation scheme approved by the P&H HC, though the CIT(A) had assigned nil value to the goodwill since no value was recorded in the amalgamating company's books. Relying on Eltek SGS Pvt. Ltd. (Del HC), the ITAT held that depreciation on acquired/created goodwill following amalgamation for AYs 2015-16 and 2016-17 was justified, thereby reversing the revenue's disallowance.
The ITAT ruled in favor of the assessee regarding depreciation claimed on goodwill acquired through amalgamation. The Tribunal found that neither the AO nor CIT(A) had questioned the valuation of goodwill created pursuant to the amalgamation scheme approved by the P&H HC, though the CIT(A) had assigned nil value to the goodwill since no value was recorded in the amalgamating company's books. Relying on Eltek SGS Pvt. Ltd. (Del HC), the ITAT held that depreciation on acquired/created goodwill following amalgamation for AYs 2015-16 and 2016-17 was justified, thereby reversing the revenue's disallowance.
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