https://www.taxtmi.com/caselaws?id=433465 In a slump sale of a passive infrastructure undertaking, depreciation was allowed on the transferee's actual purchase cost because the transferor's written down value and the special rules on holding-subsidiary transfers or depreciation apportionment did not apply. Estimated site restoration cost could not be included in actual cost under section 43(1) as it was a future dismantling expense not incurred up to first use, so depreciation on that component was disallowed. Depreciation on new assets was also allowed where invoices and supporting records established the additions. Under section 40(a)(ia), disallowance failed for tower rent below the TDS threshold and for security charges treated as manpower supply, but was sustained for unsupported remaining expenses. en-us Wed, 04 Jan 2023 00:00:00 +0530 Tue, 31 Jan 2023 08:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433465 In a slump sale of a passive infrastructure undertaking, depreciation was allowed on the transferee's actual purchase cost because the transferor's written down value and the special rules on holding-subsidiary transfers or depreciation apportionment did not apply. Estimated site restoration cost could not be included in actual cost under section 43(1) as it was a future dismantling expense not incurred up to first use, so depreciation on that component was disallowed. Depreciation on new assets was also allowed where invoices and supporting records established the additions. Under section 40(a)(ia), disallowance failed for tower rent below the TDS threshold and for security charges treated as manpower supply, but was sustained for unsupported remaining expenses. Case-Laws Income Tax Wed, 04 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433465