https://www.taxtmi.com/caselaws?id=775099 ITAT Mumbai allowed the assessee's appeal on multiple grounds. The Tribunal permitted depreciation on goodwill arising from excess consideration paid in slump sale acquisitions, following its coordinate bench decision. Set-off of brought forward unabsorbed depreciation from AY 2008-09 was allowed, following Govind Nagar Sugar Ltd precedent. Transfer pricing adjustments were deleted regarding AMP expenses as TPO improperly applied Bright Line Test without statutory mandate, citing Sony Ericson case. For import transactions, Satyatej Commercial Co. Ltd was directed to be included as comparable. In indenting commission benchmarking, Hand Innovations Inc. and RG Medical Diagnostics were excluded due to similar product profiles and territories as previously excluded companies. The TP adjustment on expense reimbursement was deleted as TPO incorrectly treated arm's length price as NIL without proper comparable search, referencing EKL Appliances Ltd judgment. en-us Wed, 16 Jul 2025 00:00:00 +0530 Sat, 19 Jul 2025 08:25:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775099 ITAT Mumbai allowed the assessee's appeal on multiple grounds. The Tribunal permitted depreciation on goodwill arising from excess consideration paid in slump sale acquisitions, following its coordinate bench decision. Set-off of brought forward unabsorbed depreciation from AY 2008-09 was allowed, following Govind Nagar Sugar Ltd precedent. Transfer pricing adjustments were deleted regarding AMP expenses as TPO improperly applied Bright Line Test without statutory mandate, citing Sony Ericson case. For import transactions, Satyatej Commercial Co. Ltd was directed to be included as comparable. In indenting commission benchmarking, Hand Innovations Inc. and RG Medical Diagnostics were excluded due to similar product profiles and territories as previously excluded companies. The TP adjustment on expense reimbursement was deleted as TPO incorrectly treated arm's length price as NIL without proper comparable search, referencing EKL Appliances Ltd judgment. Case-Laws Income Tax Wed, 16 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775099