Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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.