Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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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