ITAT allows depreciation on goodwill in slump sales, disallows TP adjustments on AMP expenses under Bright Line Test

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....The ITAT directed the AO to treat the excess consideration paid in slump sale transactions as goodwill and allow depreciation accordingly, following a coordinate bench's precedent. The tribunal allowed the set-off of brought forward unabsorbed depreciation, distinguishing it from business loss. Transfer Pricing adjustments on AMP expenses were disallowed due to lack of evidence of association or statutory basis for the Bright Line Test. The tribunal directed inclusion of Satyatej Commercial Co. Ltd. as a comparable for import of finished goods transactions, excluding freight costs. It also ordered exclusion of Hand Innovations Inc. and RG Medical Diagnostics for benchmarking indenting commission transactions based on product and territorial.........