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 HC affirmed that the assessee is not entitled to depreciation under s.32 because it did not become an "owner" (wholly or partly) of the common infrastructural assets; a long-term leasehold or usage right does not satisfy statutory ownership required for claiming depreciation. The court upheld the disallowance of depreciation but held that the contribution towards infrastructure is not a capitalizable enhancement of building; instead, given contractual refundability diminishing at 5% per annum, the amounts must be amortised and treated as revenue deductions to the extent they crystallise (5% per annum) when they become non-refundable. The Tribunal's rejection of the revenue claim was disturbed to that extent; overall decision on depreciation was against the assessee.
The HC affirmed that the assessee is not entitled to depreciation under s.32 because it did not become an "owner" (wholly or partly) of the common infrastructural assets; a long-term leasehold or usage right does not satisfy statutory ownership required for claiming depreciation. The court upheld the disallowance of depreciation but held that the contribution towards infrastructure is not a capitalizable enhancement of building; instead, given contractual refundability diminishing at 5% per annum, the amounts must be amortised and treated as revenue deductions to the extent they crystallise (5% per annum) when they become non-refundable. The Tribunal's rejection of the revenue claim was disturbed to that extent; overall decision on depreciation was against the assessee.
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