Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Depreciation at the higher rate for life-saving medical equipment was denied where the assessee's operation theatre, air pipeline system, anaesthesia trolley system and stabilizer were not specifically listed in the depreciation table and were not remotely identical to the notified equipment. On that basis, allowance of depreciation at 40% was treated as a mistake apparent from the record, and rectification under section 154 was upheld. The Tribunal sustained restriction of depreciation to 15% and rejected reliance on the cited High Court ruling because that case involved equipment found identical to the specified machinery, which was not the position here.
Depreciation at the higher rate for life-saving medical equipment was denied where the assessee's operation theatre, air pipeline system, anaesthesia trolley system and stabilizer were not specifically listed in the depreciation table and were not remotely identical to the notified equipment. On that basis, allowance of depreciation at 40% was treated as a mistake apparent from the record, and rectification under section 154 was upheld. The Tribunal sustained restriction of depreciation to 15% and rejected reliance on the cited High Court ruling because that case involved equipment found identical to the specified machinery, which was not the position here.
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