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    <title>2026 (1) TMI 248 - ITAT MUMBAI</title>
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    <description>Depreciation on manufacturing and supply/maintenance contracts acquired under slump sale was held allowable as depreciation on eligible intangible assets, following co-ordinate bench precedent; the disallowance was reversed. Claim for brought-forward and unabsorbed depreciation was held consequential to outcomes in prior years; the AO was directed to allow it in conformity with tribunal orders for earlier AYs. For TP on purchase of finished goods and analysers, the TPO/AO was directed to include a specified comparable for benchmarking; adjustment was to be recomputed. For indenting commission, exclusion of two comparables was remanded for verification of agreements, with direction to exclude if functionally similar to earlier excluded entities; adjustment was set aside. TP adjustment was restricted to AE transactions, not entity-level. Double disallowance of reimbursed expenses was to be deleted on verification, and reimbursement ALP at nil was rejected; relief granted. TDS/TCS/advance tax credits for merged entities were to be allowed after AO verification.</description>
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    <pubDate>Fri, 02 Jan 2026 00:00:00 +0530</pubDate>
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      <description>Depreciation on manufacturing and supply/maintenance contracts acquired under slump sale was held allowable as depreciation on eligible intangible assets, following co-ordinate bench precedent; the disallowance was reversed. Claim for brought-forward and unabsorbed depreciation was held consequential to outcomes in prior years; the AO was directed to allow it in conformity with tribunal orders for earlier AYs. For TP on purchase of finished goods and analysers, the TPO/AO was directed to include a specified comparable for benchmarking; adjustment was to be recomputed. For indenting commission, exclusion of two comparables was remanded for verification of agreements, with direction to exclude if functionally similar to earlier excluded entities; adjustment was set aside. TP adjustment was restricted to AE transactions, not entity-level. Double disallowance of reimbursed expenses was to be deleted on verification, and reimbursement ALP at nil was rejected; relief granted. TDS/TCS/advance tax credits for merged entities were to be allowed after AO verification.</description>
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