Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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