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    <title>2024 (4) TMI 257 - ITAT AHMEDABAD</title>
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    <description>Employees&#039; contribution to provident fund was treated as subject to the section 43B payment discipline, so the disallowance was upheld. Interest capitalised on capital work in progress was not disallowed under section 36(1)(iii) because the assessee&#039;s own funds were found sufficient, negativing any borrowing nexus. A gift of plots between companies was held capable of falling outside section 50C, since a valid gift by an authorised company is covered by the transfer exclusion in section 47(iii). Depreciation on software licence was allowed at the prescribed computer software rate, as software used with computers was treated as part of the computer system.</description>
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      <link>https://www.taxtmi.com/caselaws?id=751076</link>
      <description>Employees&#039; contribution to provident fund was treated as subject to the section 43B payment discipline, so the disallowance was upheld. Interest capitalised on capital work in progress was not disallowed under section 36(1)(iii) because the assessee&#039;s own funds were found sufficient, negativing any borrowing nexus. A gift of plots between companies was held capable of falling outside section 50C, since a valid gift by an authorised company is covered by the transfer exclusion in section 47(iii). Depreciation on software licence was allowed at the prescribed computer software rate, as software used with computers was treated as part of the computer system.</description>
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