Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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