Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Transfer of 22 self-generated registered trademarks was held to be a transfer of intangible assets distinct from goodwill, so proceeds did not attract capital gains computation under sections 48 and 55 because no ascertainable cost of acquisition existed; the 2001 amendment to the definition of cost of acquisition for trademarks was held prospective from 01.04.2002 and inapplicable. Revenue's attempts to characterise the receipt as business income or recoupment were rejected on the facts, and adoption of a DCF valuation did not alter legal character. The claimed short-term capital loss was allowed in view of applicable precedent; the Tribunal's conclusions were upheld and appeals dismissed.
Transfer of 22 self-generated registered trademarks was held to be a transfer of intangible assets distinct from goodwill, so proceeds did not attract capital gains computation under sections 48 and 55 because no ascertainable cost of acquisition existed; the 2001 amendment to the definition of cost of acquisition for trademarks was held prospective from 01.04.2002 and inapplicable. Revenue's attempts to characterise the receipt as business income or recoupment were rejected on the facts, and adoption of a DCF valuation did not alter legal character. The claimed short-term capital loss was allowed in view of applicable precedent; the Tribunal's conclusions were upheld and appeals dismissed.
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