Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Depreciation on goodwill arising from an amalgamation is not allowable where the goodwill was not capitalised or brought into the relevant block of intangible assets, because depreciation operates through the block-of-assets mechanism and requires recognition of actual cost and opening written down value; consequence: the goodwill claim is rejected. Separately, denial of intra-year set-off of losses of a SEZ unit was remitted for factual verification since explanation permitting depreciation despite non-claim applies and the assessing officer must examine existence of depreciable assets, business use and WDV; consequence: the Dahej unit claim is sent back for verification and recomputation after hearing the assessee.
Depreciation on goodwill arising from an amalgamation is not allowable where the goodwill was not capitalised or brought into the relevant block of intangible assets, because depreciation operates through the block-of-assets mechanism and requires recognition of actual cost and opening written down value; consequence: the goodwill claim is rejected. Separately, denial of intra-year set-off of losses of a SEZ unit was remitted for factual verification since explanation permitting depreciation despite non-claim applies and the assessing officer must examine existence of depreciable assets, business use and WDV; consequence: the Dahej unit claim is sent back for verification and recomputation after hearing the assessee.
Note: It is a system-generated summary and is for quick reference only.
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