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Trade receivables under TNMM were treated as integral to the international transactions, so a separate notional interest adjustment was deleted where working capital adjustment had already captured the receivables impact and no distinct financing arrangement was shown. Goodwill arising on amalgamation was accepted as a depreciable acquired intangible, and depreciation was allowed. Product registration and regulatory approval were held to be revenue in nature because they facilitated existing business operations rather than creating a capital asset. For section 80-IC, the Tribunal upheld full deduction on manufacturing profits without hypothetical brand-royalty allocation, included scrap income as derived from manufacturing, and confirmed 100% deduction after substantial expansion in line with Aarham Softronics.
Trade receivables under TNMM were treated as integral to the international transactions, so a separate notional interest adjustment was deleted where working capital adjustment had already captured the receivables impact and no distinct financing arrangement was shown. Goodwill arising on amalgamation was accepted as a depreciable acquired intangible, and depreciation was allowed. Product registration and regulatory approval were held to be revenue in nature because they facilitated existing business operations rather than creating a capital asset. For section 80-IC, the Tribunal upheld full deduction on manufacturing profits without hypothetical brand-royalty allocation, included scrap income as derived from manufacturing, and confirmed 100% deduction after substantial expansion in line with Aarham Softronics.
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