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    <title>2026 (8) TMI 1476 - ITAT AHMEDABAD</title>
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    <description>Depreciation on goodwill arising from amalgamation, and on brands and trade names transferred through demerger, was treated as allowable where consistent prior treatment applied and no distinguishing facts existed. For captive-power inter-unit electricity transfers, market value was the price paid by the recipient manufacturing unit for open-market electricity, rather than the generator-to-distributor tariff. Steam transferred from an eligible captive-power unit to a non-eligible unit could not be assigned nil value merely because it was a by-product; arm&#039;s length valuation may rely on reliable external market comparables rather than internal cost. The disallowances and transfer-pricing adjustments were deleted.</description>
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