Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Goodwill arising from amalgamation of a running business was treated as a depreciable intangible asset because it represented commercial rights covered by the depreciation provision, and the Tribunal followed its earlier years' view in the absence of any change in facts or law. The deletion of disallowance of depreciation on goodwill was upheld. For captive power transfers, the Tribunal accepted the internal CUP benchmark based on the consumer tariff charged by the distribution company for valuing inter-unit electricity sales, holding that regulatory tariff was not the proper market benchmark. On that basis, the transfer pricing adjustment affecting the section 80IA deduction was deleted and the assessee's claim was sustained.
Goodwill arising from amalgamation of a running business was treated as a depreciable intangible asset because it represented commercial rights covered by the depreciation provision, and the Tribunal followed its earlier years' view in the absence of any change in facts or law. The deletion of disallowance of depreciation on goodwill was upheld. For captive power transfers, the Tribunal accepted the internal CUP benchmark based on the consumer tariff charged by the distribution company for valuing inter-unit electricity sales, holding that regulatory tariff was not the proper market benchmark. On that basis, the transfer pricing adjustment affecting the section 80IA deduction was deleted and the assessee's claim was sustained.
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