Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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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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