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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ITAT ruled against PCIT's interpretation of depreciation computation under Section 32(1)(ii) and 43(6)(c). The tribunal rejected PCIT's method requiring brought forward additional depreciation from AY 2017-18 to be first reduced from opening WDV before computing current year's depreciation for AY 2018-19. ITAT affirmed depreciation must be calculated on WDV of block assets per prescribed rates, with WDV computation only adjusted for asset additions and disposals during the year. The tribunal found assessee's depreciation claim aligned with ITR utility format and Tax Audit Report requirements. Since no erroneous treatment prejudicial to revenue interest was established, assessee's appeal was allowed, invalidating revision under s.263.
ITAT ruled against PCIT's interpretation of depreciation computation under Section 32(1)(ii) and 43(6)(c). The tribunal rejected PCIT's method requiring brought forward additional depreciation from AY 2017-18 to be first reduced from opening WDV before computing current year's depreciation for AY 2018-19. ITAT affirmed depreciation must be calculated on WDV of block assets per prescribed rates, with WDV computation only adjusted for asset additions and disposals during the year. The tribunal found assessee's depreciation claim aligned with ITR utility format and Tax Audit Report requirements. Since no erroneous treatment prejudicial to revenue interest was established, assessee's appeal was allowed, invalidating revision under s.263.
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