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    <title>2026 (4) TMI 1776 - ITAT AHMEDABAD</title>
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    <description>Depreciation was held allowable on goodwill arising from an amalgamation, treating it as an intangible asset under section 32(1)(ii) because it represented consideration for acquisition of a running business with commercial rights and business advantages; the disallowance was deleted in the assessee&#039;s favour. Transfer pricing adjustment on inter-unit sale of electricity for computing deduction under section 80IA was rejected because the assessee&#039;s internal CUP, based on the distribution company&#039;s consumer tariff, was accepted as a reliable benchmark for a homogeneous commodity; the substitute rate adopted by the TPO was not accepted and the deduction was upheld.</description>
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      <description>Depreciation was held allowable on goodwill arising from an amalgamation, treating it as an intangible asset under section 32(1)(ii) because it represented consideration for acquisition of a running business with commercial rights and business advantages; the disallowance was deleted in the assessee&#039;s favour. Transfer pricing adjustment on inter-unit sale of electricity for computing deduction under section 80IA was rejected because the assessee&#039;s internal CUP, based on the distribution company&#039;s consumer tariff, was accepted as a reliable benchmark for a homogeneous commodity; the substitute rate adopted by the TPO was not accepted and the deduction was upheld.</description>
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