https://www.taxtmi.com/caselaws?id=785048 Dispute concerns transfer pricing, depreciation on goodwill from a slump sale, and allowability of bad debts in relation to an India Business Segment spin-off. The tribunal accepted that transition services under a TSA were bona fide due to corporate spin-off and deleted the TP adjustment. For operational and business support comparables the tribunal excluded certain entities for functional dissimilarity, retained Cosmic Global, and remitted Silgate and BNR Udyog for fresh functional/employee-cost analysis. Depreciation on goodwill recognized post-transfer was allowed following prior coordinate bench precedent. Bad debts written off were held allowable as revenue-account losses where provisions were offered to tax and no recovery was alleged. en-us Wed, 26 Nov 2025 00:00:00 +0530 Fri, 16 Jan 2026 08:03:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785048 Dispute concerns transfer pricing, depreciation on goodwill from a slump sale, and allowability of bad debts in relation to an India Business Segment spin-off. The tribunal accepted that transition services under a TSA were bona fide due to corporate spin-off and deleted the TP adjustment. For operational and business support comparables the tribunal excluded certain entities for functional dissimilarity, retained Cosmic Global, and remitted Silgate and BNR Udyog for fresh functional/employee-cost analysis. Depreciation on goodwill recognized post-transfer was allowed following prior coordinate bench precedent. Bad debts written off were held allowable as revenue-account losses where provisions were offered to tax and no recovery was alleged. Case-Laws Income Tax Wed, 26 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785048