https://www.taxtmi.com/caselaws?id=461974 ITAT Mumbai ruled in favor of the assessee on multiple grounds. The tribunal allowed depreciation on business rights, noting the transaction was determined at arm's length in previous years and no international transaction existed in AY 2016-17. Regarding equity share purchase adjustments, the tribunal held that capital transactions don't fall under international transaction provisions as no income arises. The tribunal allowed depreciation on intangible assets, finding commercial rights qualify under Section 32(1)(i) and noting prior acceptance by AO. On Section 14A disallowance, the tribunal limited it to Rs. 54 lakhs as computed by assessee, ruling no borrowed funds were used and disallowance cannot be added to book-profit under Section 115JB. en-us Fri, 09 Dec 2022 00:00:00 +0530 Fri, 09 May 2025 15:32:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461974 ITAT Mumbai ruled in favor of the assessee on multiple grounds. The tribunal allowed depreciation on business rights, noting the transaction was determined at arm's length in previous years and no international transaction existed in AY 2016-17. Regarding equity share purchase adjustments, the tribunal held that capital transactions don't fall under international transaction provisions as no income arises. The tribunal allowed depreciation on intangible assets, finding commercial rights qualify under Section 32(1)(i) and noting prior acceptance by AO. On Section 14A disallowance, the tribunal limited it to Rs. 54 lakhs as computed by assessee, ruling no borrowed funds were used and disallowance cannot be added to book-profit under Section 115JB. Case-Laws Income Tax Fri, 09 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461974