Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Depreciation on goodwill arising on amalgamation is treated as allowable because such goodwill constitutes an intangible asset and is eligible for depreciation; earlier decisions relied upon by the taxpayer support this principle and the appellate authority accepted the claim, resulting in allowance of depreciation. The legal point emphasises that goodwill recorded on merger qualifies as depreciable intangible property for tax purposes, and reliance on prior accounting recognition and precedent was determinative of the deductibility outcome.
Depreciation on goodwill arising on amalgamation is treated as allowable because such goodwill constitutes an intangible asset and is eligible for depreciation; earlier decisions relied upon by the taxpayer support this principle and the appellate authority accepted the claim, resulting in allowance of depreciation. The legal point emphasises that goodwill recorded on merger qualifies as depreciable intangible property for tax purposes, and reliance on prior accounting recognition and precedent was determinative of the deductibility outcome.
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