Goodwill Depreciation disallowed as artificial creation; buy-back distributed-income tax sustained and valuation rejected on related-party transaction.

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....The note addresses two connected tax issues: allowability of depreciation on goodwill recognised on an intra-group amalgamation, and liability to tax on share buy-back as distributed income. It concludes that the booked goodwill was an artificial creation in a related-party amalgamation lacking independent commercial advantage and real value-generation; accordingly depreciation/amortisation claims were disallowed. On buy-back, the Tribunal sustained the Assessing Officer's computation of distributed income because the true net assets did not support the assessee's claimed receipt on issue and the related-party buy-back was a colourable device; 115QA levy confirmed.....