Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Adjustment under s.143(1)(a) reducing depreciation on goods carriage vehicles from 30% to 15% was invalid because only arithmetical errors or incorrect claims apparent from the return can be adjusted, whereas the applicable depreciation rate is a debatable matter requiring examination beyond the limited, mechanical scope of processing. On merits, higher depreciation at 30% was allowable for goods carriage vehicles run on hire, including vehicles used in the assessee's transportation business for carrying goods on hire, consistent with settled law. Consequently, the disallowance/addition made while processing the return was directed to be deleted and the appeal was allowed. - ITAT
Adjustment under s.143(1)(a) reducing depreciation on goods carriage vehicles from 30% to 15% was invalid because only arithmetical errors or incorrect claims apparent from the return can be adjusted, whereas the applicable depreciation rate is a debatable matter requiring examination beyond the limited, mechanical scope of processing. On merits, higher depreciation at 30% was allowable for goods carriage vehicles run on hire, including vehicles used in the assessee's transportation business for carrying goods on hire, consistent with settled law. Consequently, the disallowance/addition made while processing the return was directed to be deleted and the appeal was allowed. - ITAT
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