https://www.taxtmi.com/caselaws?id=28735 Ownership for depreciation and development rebate depends on the real nature of the transaction and the parties' intention as to when property in specific goods passes under section 19 of the Sale of Goods Act. Where machinery was imported for the assessee's contract, used in its business, with cost recoverable from the assessee and the Government's lien operating only as security until payment and completion, the machinery was treated as belonging to the assessee in substance. The balance-sheet treatment also supported that conclusion. The assessee was therefore regarded as owner for sections 32 and 33 of the Income-tax Act, 1961, and was entitled to depreciation and development rebate. en-us Mon, 07 Sep 1981 00:00:00 +0530 Thu, 25 Feb 2010 12:45:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28735 Ownership for depreciation and development rebate depends on the real nature of the transaction and the parties' intention as to when property in specific goods passes under section 19 of the Sale of Goods Act. Where machinery was imported for the assessee's contract, used in its business, with cost recoverable from the assessee and the Government's lien operating only as security until payment and completion, the machinery was treated as belonging to the assessee in substance. The balance-sheet treatment also supported that conclusion. The assessee was therefore regarded as owner for sections 32 and 33 of the Income-tax Act, 1961, and was entitled to depreciation and development rebate. Case-Laws Income Tax Mon, 07 Sep 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28735