Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
Where liability to incur construction expenditure had already accrued under the business transaction, the Court applied the mercantile system and the Calcutta Company principle to allow deduction of the estimated expense on accrual basis; the concurrent finding permitting the construction deduction was upheld. In the sale-and-lease-back arrangement involving cinematographic rights, title had passed to the assessee and the vendor thereafter remained only as lessee; mere tax-saving motive, unsupported by material, did not make the transaction a colourable device. Depreciation on the films was therefore allowed, and the Revenue failed on both issues.
Where liability to incur construction expenditure had already accrued under the business transaction, the Court applied the mercantile system and the Calcutta Company principle to allow deduction of the estimated expense on accrual basis; the concurrent finding permitting the construction deduction was upheld. In the sale-and-lease-back arrangement involving cinematographic rights, title had passed to the assessee and the vendor thereafter remained only as lessee; mere tax-saving motive, unsupported by material, did not make the transaction a colourable device. Depreciation on the films was therefore allowed, and the Revenue failed on both issues.
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