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 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.
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