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 denied depreciation claim for highway infrastructure. The tribunal held that the assessee was merely a licensee without ownership rights over the immovable assets, which belonged to NHAI. Per section 32 of Income Tax Act, depreciation requires asset ownership, either wholly or partially. The construction, erected with licensor's permission under section 52 of Indian Easements Act, 1882, did not confer ownership status. Referencing precedent in North Karnataka Expressway Ltd., the tribunal emphasized that National Highway ownership remains vested with the Union, irrespective of private sector involvement in development and maintenance. Consequently, the assessee's appeal was dismissed, affirming that the definition of "owner" cannot override special legislative provisions governing national highway ownership.
ITAT denied depreciation claim for highway infrastructure. The tribunal held that the assessee was merely a licensee without ownership rights over the immovable assets, which belonged to NHAI. Per section 32 of Income Tax Act, depreciation requires asset ownership, either wholly or partially. The construction, erected with licensor's permission under section 52 of Indian Easements Act, 1882, did not confer ownership status. Referencing precedent in North Karnataka Expressway Ltd., the tribunal emphasized that National Highway ownership remains vested with the Union, irrespective of private sector involvement in development and maintenance. Consequently, the assessee's appeal was dismissed, affirming that the definition of "owner" cannot override special legislative provisions governing national highway ownership.
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