Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
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...
Depreciation on a trademark forming part of a post-amalgamation...
Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt income.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Depreciation on a trademark forming part of a post-amalgamation block of intangible assets was held allowable on the opening written down value, because the claim had been accepted in scrutiny in the first year, no change in facts was shown, and the Revenue could not disturb the settled position by questioning the asset's existence later. For book profit under section 115JB, the adjustment linked to section 14A was deleted because clause (f) of Explanation 1 must be computed independently and not by importing Rule 8D. Section 14A disallowance was also held inapplicable where no exempt income was earned, and the Finance Act, 2022 amendment was treated as prospective from assessment year 2022-23.
Depreciation on a trademark forming part of a post-amalgamation block of intangible assets was held allowable on the opening written down value, because the claim had been accepted in scrutiny in the first year, no change in facts was shown, and the Revenue could not disturb the settled position by questioning the asset's existence later. For book profit under section 115JB, the adjustment linked to section 14A was deleted because clause (f) of Explanation 1 must be computed independently and not by importing Rule 8D. Section 14A disallowance was also held inapplicable where no exempt income was earned, and the Finance Act, 2022 amendment was treated as prospective from assessment year 2022-23.
Note: It is a system-generated summary and is for quick reference only.