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    <description>Goodwill arising on amalgamation was treated as a depreciable intangible asset under section 32(1)(ii), and the absence of a goodwill entry under the pooling of interest method did not defeat the claim because accounting treatment does not govern tax computation; the depreciation claim was also entertainable at the appellate stage. Disallowance under section 14A was confined to the exempt income actually earned, in line with the applicable precedent. Business support services were held to be integral and properly benchmarkable under TNMM, so selective nil valuation of bundled services was unsustainable; functionally dissimilar comparables were excluded and similar ones retained, leading to deletion of the transfer pricing adjustment.</description>
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