Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The assessee is entitled to claim additional depreciation u/s 32(1)(iia) on electrical items forming part of plant and machinery, even if not engaged in manufacture or production. The Tribunal, following the Gujarat High Court's decision in CIT vs. Starlight Silk Mills Pvt. Ltd., held that AC plants, electric installations, and transformers are integral to plant and machinery and eligible for depreciation. Similarly, in Raw Flints (P) Ltd case, the ITAT Ahmedabad ruled that electrical installations are integral to the manufacturing process and cannot be excluded from plant and machinery. Accordingly, the assessee can claim depreciation and additional depreciation on electrical fittings constituting plant and machinery, subject to conditions u/s 32(1)(iia).
The assessee is entitled to claim additional depreciation u/s 32(1)(iia) on electrical items forming part of plant and machinery, even if not engaged in manufacture or production. The Tribunal, following the Gujarat High Court's decision in CIT vs. Starlight Silk Mills Pvt. Ltd., held that AC plants, electric installations, and transformers are integral to plant and machinery and eligible for depreciation. Similarly, in Raw Flints (P) Ltd case, the ITAT Ahmedabad ruled that electrical installations are integral to the manufacturing process and cannot be excluded from plant and machinery. Accordingly, the assessee can claim depreciation and additional depreciation on electrical fittings constituting plant and machinery, subject to conditions u/s 32(1)(iia).
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