Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Disallowance on account of depreciation on the amount written back from Capital Reserve - Determination of Cost of capital assets u/s 43(6) - The waiver of loan in the earlier year has no impact either on the actual cost u/s 43(1) or the w.d.v. u/s 43(6) for the year under consideration and further section 2(24)(xviii) also does not envelope such waiver within the ambit of `income’ for the extant year. In that view of the matter, depreciation has to be allowed on the w.d.v. of the block of Machinery at the gross value without reducing the waiver of loan therefrom. Ex consequenti, disallowance of depreciation cannot stand and is hereby deleted. - AT
Disallowance on account of depreciation on the amount written back from Capital Reserve - Determination of Cost of capital assets u/s 43(6) - The waiver of loan in the earlier year has no impact either on the actual cost u/s 43(1) or the w.d.v. u/s 43(6) for the year under consideration and further section 2(24)(xviii) also does not envelope such waiver within the ambit of `income’ for the extant year. In that view of the matter, depreciation has to be allowed on the w.d.v. of the block of Machinery at the gross value without reducing the waiver of loan therefrom. Ex consequenti, disallowance of depreciation cannot stand and is hereby deleted. - AT
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