TMI Blog2023 (9) TMI 896X X X X Extracts X X X X X X X X Extracts X X X X ..... ores. The assessee has also submitted valuation reports of independent valuer. On the remaining intangibles assessee capitalized the same but did not claim any depreciation or claim it as any revenue expenditure. But notwithstanding that TPO has given an opinion that the weightage that the assessee gave to different territories for which the credit card business was acquired from the HSBC was not correct. Assessee had given higher weightage to India territory as credit card penetration was low in comparison to other countries which showed that there was more scope to increase the business in India. According to the TPO because the credit card business was much more advance in other countries a higher weightage should have been given t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on, which is required to be considered is question (D), which reads as under: Whether on the facts and in the circumstances of the case and in law, the Hon ble Income Tax Appellate Tribunal was justified in stating that TPO has not rejected the valuation of assessee on the basis of any objective reasoning, ignoring the facts that TPO has very objectively analyzed the facts of the case and rightly rejected the valuation of assessee? In our view this also would not raise any substantial question of law. 2. Respondent-Assessee is subsidiary of Global Payments Asia Pacific (India) Private Limited and is engaged in merchant acquiring and credit card processing business. During the year under consideration namely Assessment Year 200 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s intangibles one head was trade-mark. The cost of acquiring the trade-mark was capitalized by the assessee and depreciation was claimed by computing taxable income. The value attributed to trade-mark was only Rs. 46.57 lacs approximately out of the total consideration of Rs. 28.51 Crores. The assessee has also submitted valuation reports of independent valuer. 4. On the remaining intangibles assessee capitalized the same but did not claim any depreciation or claim it as any revenue expenditure. But notwithstanding that TPO has given an opinion that the weightage that the assessee gave to different territories for which the credit card business was acquired from the HSBC was not correct. Assessee had given higher weightage to India terri ..... X X X X Extracts X X X X X X X X Extracts X X X X
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