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...
ITAT decision involving corporate amalgamation and tax treatment of goodwill and interest expenses. The tribunal held that depreciation on goodwill arising from amalgamation is permissible under section 32(1), interpreting "user" broadly for intangible assets. The tribunal emphasized that goodwill created through NCLT-approved amalgamation qualifies for depreciation. Additionally, interest paid on loan borrowed for acquiring controlling interest in a company is deductible under section 36(1)(iii), as the share acquisition constitutes business expansion. The tribunal rejected the Assessing Officer's disallowance, upholding the CIT(A)'s order and allowing the assessee's claims for depreciation and interest expense deduction.
ITAT decision involving corporate amalgamation and tax treatment of goodwill and interest expenses. The tribunal held that depreciation on goodwill arising from amalgamation is permissible under section 32(1), interpreting "user" broadly for intangible assets. The tribunal emphasized that goodwill created through NCLT-approved amalgamation qualifies for depreciation. Additionally, interest paid on loan borrowed for acquiring controlling interest in a company is deductible under section 36(1)(iii), as the share acquisition constitutes business expansion. The tribunal rejected the Assessing Officer's disallowance, upholding the CIT(A)'s order and allowing the assessee's claims for depreciation and interest expense deduction.
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