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    <title>2024 (1) TMI 264 - ITAT AHMEDABAD</title>
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    <description>Oil wells and operational oil-field equipment were treated as plant and machinery for depreciation under section 32, and the higher depreciation rate for mineral oil concerns was applied with recomputation of opening WDV subject to verification of additions. The deduction claim under section 80IB(9) for the Dholka oilfield was remanded because the issue depended on the pending Supreme Court outcome on the relevant Explanation. Depreciation on goodwill or other intangible/commercial rights was also restored for verification of the asset&#039;s nature and supporting documents. Subscription charges and audit services were held not to constitute fees for technical services, so disallowance under section 40(a)(ia) was deleted, while reimbursement and training-related payments to the head office were sent back for fresh treaty and factual examination.</description>
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      <link>https://www.taxtmi.com/caselaws?id=447865</link>
      <description>Oil wells and operational oil-field equipment were treated as plant and machinery for depreciation under section 32, and the higher depreciation rate for mineral oil concerns was applied with recomputation of opening WDV subject to verification of additions. The deduction claim under section 80IB(9) for the Dholka oilfield was remanded because the issue depended on the pending Supreme Court outcome on the relevant Explanation. Depreciation on goodwill or other intangible/commercial rights was also restored for verification of the asset&#039;s nature and supporting documents. Subscription charges and audit services were held not to constitute fees for technical services, so disallowance under section 40(a)(ia) was deleted, while reimbursement and training-related payments to the head office were sent back for fresh treaty and factual examination.</description>
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