Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Deduction u/s 80IAB on the disallowance of depreciation on Water-use Rights (Intangibles Asset) - The Tribunal acknowledged the payment made by the assessee for water-use rights but concurred with the AO that such rights do not constitute a depreciable capital asset. The Tribunal upheld the AO's decision to disallow depreciation on water-use rights. - However, the Tribunal found merit in the appellant's claim. It observed that the disallowance of depreciation indeed enhanced the profit of the undertaking, making it eligible for deduction under Section 80IAB. The Tribunal cited a CBDT Circular supporting this interpretation. Consequently, it directed the AO to allow the deduction under Section 80IAB on the disallowed depreciation, providing consequential relief to the assessee.
Deduction u/s 80IAB on the disallowance of depreciation on Water-use Rights (Intangibles Asset) - The Tribunal acknowledged the payment made by the assessee for water-use rights but concurred with the AO that such rights do not constitute a depreciable capital asset. The Tribunal upheld the AO's decision to disallow depreciation on water-use rights. - However, the Tribunal found merit in the appellant's claim. It observed that the disallowance of depreciation indeed enhanced the profit of the undertaking, making it eligible for deduction under Section 80IAB. The Tribunal cited a CBDT Circular supporting this interpretation. Consequently, it directed the AO to allow the deduction under Section 80IAB on the disallowed depreciation, providing consequential relief to the assessee.
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