SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
The Income Tax Appellate Tribunal (ITAT) adjudicated on two issues: disallowance of excess depreciation claimed on a building and disallowance of expenses. Regarding the first issue, the ITAT held that the legal fiction u/s 50C for computing capital gains cannot be extended to Section 32 for claiming depreciation on a block of assets. The actual sale consideration, not the notional value u/s 50C, should be reduced from the opening written down value (WDV) for computing depreciation. The disallowance made by the lower authorities was set aside. Concerning the second issue, the assessee agreed to produce necessary evidence supporting the expenses claimed. The matter was restored to the Assessing Officer to verify the documentary evidence and decide accordingly.
The Income Tax Appellate Tribunal (ITAT) adjudicated on two issues: disallowance of excess depreciation claimed on a building and disallowance of expenses. Regarding the first issue, the ITAT held that the legal fiction u/s 50C for computing capital gains cannot be extended to Section 32 for claiming depreciation on a block of assets. The actual sale consideration, not the notional value u/s 50C, should be reduced from the opening written down value (WDV) for computing depreciation. The disallowance made by the lower authorities was set aside. Concerning the second issue, the assessee agreed to produce necessary evidence supporting the expenses claimed. The matter was restored to the Assessing Officer to verify the documentary evidence and decide accordingly.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
