Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
ITAT held that, under S.32 read with S.43(6)(c) and Rule 5, depreciation is governed by the "block of assets" concept and the individual identity of a depreciable asset is extinguished once it forms part of the block. In the case of Assessee X, the motor car was part of the "Motor Cars" block (15%), and the sale consideration of Rs. 5,60,000 had already been reduced from the block while computing depreciation in the return. ITAT held that no separate taxable profit arises on sale of an individual asset within the block and that taxing the book profit of Rs. 4,83,894 amounted to impermissible double taxation. As the AO cited no enabling provision and CIT(A) gave no cogent reasoning, the addition was deleted. Appeal allowed in favour of Assessee X.
ITAT held that, under S.32 read with S.43(6)(c) and Rule 5, depreciation is governed by the "block of assets" concept and the individual identity of a depreciable asset is extinguished once it forms part of the block. In the case of Assessee X, the motor car was part of the "Motor Cars" block (15%), and the sale consideration of Rs. 5,60,000 had already been reduced from the block while computing depreciation in the return. ITAT held that no separate taxable profit arises on sale of an individual asset within the block and that taxing the book profit of Rs. 4,83,894 amounted to impermissible double taxation. As the AO cited no enabling provision and CIT(A) gave no cogent reasoning, the addition was deleted. Appeal allowed in favour of Assessee X.
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