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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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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