Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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