Imported analyser diagnostic cartridges treated as accessories with analyser system, not standalone diagnostic reagents; extended limitation and penal...
Steel-timber construction shuttering/formwork tariff classification dispute: essential character held steel, classified as shuttering under Heading 73...
Family-linked property purchases using fabricated loan agreements and benami-style arrangements held to be crime proceeds; attachment upheld, appeal d...
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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