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Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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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