https://www.taxtmi.com/caselaws?id=469585 Amortisation of goodwill was treated as a non-operating, extraordinary item and excluded from operating expenses for transfer pricing margin computation, because it did not affect ordinary day-to-day business operations. Working capital adjustment was upheld where material differences between the assessee and comparables could distort profitability, with Rule 10B(3) applied to require reasonably accurate adjustments. Depreciation on a non-compete fee was held allowable because the payment created a capital business right amounting to an intangible asset of a commercial nature. On all substantive issues, the revenue's challenge failed. en-us Wed, 23 Feb 2022 00:00:00 +0530 Tue, 23 Jun 2026 16:46:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469585 Amortisation of goodwill was treated as a non-operating, extraordinary item and excluded from operating expenses for transfer pricing margin computation, because it did not affect ordinary day-to-day business operations. Working capital adjustment was upheld where material differences between the assessee and comparables could distort profitability, with Rule 10B(3) applied to require reasonably accurate adjustments. Depreciation on a non-compete fee was held allowable because the payment created a capital business right amounting to an intangible asset of a commercial nature. On all substantive issues, the revenue's challenge failed. Case-Laws Income Tax Wed, 23 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469585