Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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