https://www.taxtmi.com/caselaws?id=778630 ITAT MUMBAI - AT allowed depreciation on goodwill arising from a slump-sale acquisition, rejecting applicability of amalgamation provisions. For transfer-pricing benchmarking, the tribunal held depreciation on that goodwill and amortisation of non-compete fees are non-operating, extraordinary items and must be excluded from operating margins. Several challenged comparable-company selections and filters were remitted to the TPO/AO/CIT(A) for fresh, balanced consideration: the turnover filter must be relaxed to produce a wider comparable set; specific comparables are to be included or re-examined; a loss-making comparable is to be re-adjudicated; and the taxpayer's TNMM for certain export transactions was accepted as the appropriate method. en-us Mon, 25 Aug 2025 00:00:00 +0530 Thu, 18 Sep 2025 11:19:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778630 ITAT MUMBAI - AT allowed depreciation on goodwill arising from a slump-sale acquisition, rejecting applicability of amalgamation provisions. For transfer-pricing benchmarking, the tribunal held depreciation on that goodwill and amortisation of non-compete fees are non-operating, extraordinary items and must be excluded from operating margins. Several challenged comparable-company selections and filters were remitted to the TPO/AO/CIT(A) for fresh, balanced consideration: the turnover filter must be relaxed to produce a wider comparable set; specific comparables are to be included or re-examined; a loss-making comparable is to be re-adjudicated; and the taxpayer's TNMM for certain export transactions was accepted as the appropriate method. Case-Laws Income Tax Mon, 25 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778630