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    <title>2026 (7) TMI 1709 - ITAT DELHI</title>
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    <description>Goodwill recognised solely as an accounting entry on demerger, reflecting excess liabilities over assets of a demerged undertaking, did not constitute an international transaction because no goodwill was acquired, transferred, sold, leased, or used between associated enterprises. Its non-reporting in Form 3CEB therefore did not attract penalty. The notes further state that amortisation was added back in computing taxable income, relevant facts were disclosed for Form 3CEB preparation, the assessee had bona fide and reasonable cause, and the penalty notice was vague and mechanically issued. Penalty for non-reporting goodwill was accordingly not leviable.</description>
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    <pubDate>Wed, 22 Jul 2026 00:00:00 +0530</pubDate>
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      <title>2026 (7) TMI 1709 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=795823</link>
      <description>Goodwill recognised solely as an accounting entry on demerger, reflecting excess liabilities over assets of a demerged undertaking, did not constitute an international transaction because no goodwill was acquired, transferred, sold, leased, or used between associated enterprises. Its non-reporting in Form 3CEB therefore did not attract penalty. The notes further state that amortisation was added back in computing taxable income, relevant facts were disclosed for Form 3CEB preparation, the assessee had bona fide and reasonable cause, and the penalty notice was vague and mechanically issued. Penalty for non-reporting goodwill was accordingly not leviable.</description>
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