https://www.taxtmi.com/caselaws?id=764384 ITAT Chennai-AT ruled in favor of the assessee on two issues. First, regarding TP adjustment on CCD interest, the court held that the assessee's 11% coupon rate was within the arm's length range of 10-12.65% based on proper benchmarking analysis of 57 comparables. The TPO's determination of NIL ALP was rejected as it lacked cogent reasons and proper search methodology. Second, concerning depreciation on goodwill from slump sale, the court allowed depreciation under Section 32, holding that goodwill constitutes an intangible asset and came into existence for the first time through the business transfer agreement. en-us Tue, 10 Dec 2024 00:00:00 +0530 Wed, 08 Jan 2025 11:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764384 ITAT Chennai-AT ruled in favor of the assessee on two issues. First, regarding TP adjustment on CCD interest, the court held that the assessee's 11% coupon rate was within the arm's length range of 10-12.65% based on proper benchmarking analysis of 57 comparables. The TPO's determination of NIL ALP was rejected as it lacked cogent reasons and proper search methodology. Second, concerning depreciation on goodwill from slump sale, the court allowed depreciation under Section 32, holding that goodwill constitutes an intangible asset and came into existence for the first time through the business transfer agreement. Case-Laws Income Tax Tue, 10 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764384