Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Depreciation on acquired goodwill was allowed because the Tribunal followed its earlier orders in the assessee's own case and treated the goodwill as part of the business acquisition, with its value not restricted to nil. It rejected the Revenue's reliance on the later amendment to section 32(1)(ii), holding that the exclusion of goodwill from depreciation operates prospectively and did not apply to the year under consideration. The recalled grounds on cost of goodwill and depreciation were therefore accepted, and the appeal was allowed.
Depreciation on acquired goodwill was allowed because the Tribunal followed its earlier orders in the assessee's own case and treated the goodwill as part of the business acquisition, with its value not restricted to nil. It rejected the Revenue's reliance on the later amendment to section 32(1)(ii), holding that the exclusion of goodwill from depreciation operates prospectively and did not apply to the year under consideration. The recalled grounds on cost of goodwill and depreciation were therefore accepted, and the appeal was allowed.
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