International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
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The note addresses two connected tax issues: allowability of depreciation on goodwill recognised on an intra-group amalgamation, and liability to tax on share buy-back as distributed income. It concludes that the booked goodwill was an artificial creation in a related-party amalgamation lacking independent commercial advantage and real value-generation; accordingly depreciation/amortisation claims were disallowed. On buy-back, the Tribunal sustained the Assessing Officer's computation of distributed income because the true net assets did not support the assessee's claimed receipt on issue and the related-party buy-back was a colourable device; 115QA levy confirmed.
The note addresses two connected tax issues: allowability of depreciation on goodwill recognised on an intra-group amalgamation, and liability to tax on share buy-back as distributed income. It concludes that the booked goodwill was an artificial creation in a related-party amalgamation lacking independent commercial advantage and real value-generation; accordingly depreciation/amortisation claims were disallowed. On buy-back, the Tribunal sustained the Assessing Officer's computation of distributed income because the true net assets did not support the assessee's claimed receipt on issue and the related-party buy-back was a colourable device; 115QA levy confirmed.
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