https://www.taxtmi.com/caselaws?id=38306 The proviso to section 10(5)(a) of the Indian Income-tax Act, 1922 was treated as applicable where assets were transferred from a parent company to its wholly owned subsidiary and the surrounding circumstances supported an inference that the transfer was structured to secure depreciation on an enhanced cost. The court accepted the department's rejection of an unsupported valuation report and the adverse inference from non-production of reliable market-value material. It also accepted the departmental method of determining actual cost by taking the transferor's written down value and adding the balancing charge, holding that this was a rational basis on the facts and within the statutory discretion. en-us Mon, 08 Aug 1977 00:00:00 +0530 Mon, 05 Apr 2010 13:21:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38306 The proviso to section 10(5)(a) of the Indian Income-tax Act, 1922 was treated as applicable where assets were transferred from a parent company to its wholly owned subsidiary and the surrounding circumstances supported an inference that the transfer was structured to secure depreciation on an enhanced cost. The court accepted the department's rejection of an unsupported valuation report and the adverse inference from non-production of reliable market-value material. It also accepted the departmental method of determining actual cost by taking the transferor's written down value and adding the balancing charge, holding that this was a rational basis on the facts and within the statutory discretion. Case-Laws Income Tax Mon, 08 Aug 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38306