Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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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.
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