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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A taxpayer purchasing new plant and machinery for use for less than 180 days is entitled to claim only 50% of the additional depreciation in the first assessment year, but the remaining 50% may be carried forward to the next year. The Madras High Court in Shri T.P. Textiles applied the legislative intent behind the Finance Act, 2015 amendment and held that the proviso to the depreciation provision limits only the first-year allowance, not the total entitlement, so as to avoid discrimination between assessees using machinery for less than 180 days and those using it for longer periods.
A taxpayer purchasing new plant and machinery for use for less than 180 days is entitled to claim only 50% of the additional depreciation in the first assessment year, but the remaining 50% may be carried forward to the next year. The Madras High Court in Shri T.P. Textiles applied the legislative intent behind the Finance Act, 2015 amendment and held that the proviso to the depreciation provision limits only the first-year allowance, not the total entitlement, so as to avoid discrimination between assessees using machinery for less than 180 days and those using it for longer periods.
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