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...
The ITAT overturned the AO's disallowance of depreciation on goodwill arising from amalgamation, holding that the goodwill recognized pursuant to the approved scheme of amalgamation and valuation report is valid for depreciation claims. The AO erred by valuing intangible assets at NIL cost despite the consideration exceeding net assets acquired. Following the Supreme Court precedent, the differential amount paid over net assets constitutes goodwill, which is eligible for depreciation. Consequently, the appellate tribunal allowed the assessee's appeal, permitting depreciation on goodwill recognized on amalgamation.
The ITAT overturned the AO's disallowance of depreciation on goodwill arising from amalgamation, holding that the goodwill recognized pursuant to the approved scheme of amalgamation and valuation report is valid for depreciation claims. The AO erred by valuing intangible assets at NIL cost despite the consideration exceeding net assets acquired. Following the Supreme Court precedent, the differential amount paid over net assets constitutes goodwill, which is eligible for depreciation. Consequently, the appellate tribunal allowed the assessee's appeal, permitting depreciation on goodwill recognized on amalgamation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
