Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
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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