Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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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