https://www.taxtmi.com/caselaws?id=780492 ITAT held that the wholly-owned offshore company is a separate corporate entity and cannot be treated as the assessee's proprietary concern, allowing the taxpayer's stance. The Tribunal upheld that electrical installations form part of plant and machinery, permitting depreciation at 15% instead of 10%. A payment to settle a patent dispute was held to be a compensatory commercial expenditure deductible under Section 37; the disallowance was deleted. Grounds 1 and 2 of the appeal were allowed; the alternative plea under Section 28 was rendered academic. en-us Wed, 01 Oct 2025 00:00:00 +0530 Fri, 31 Oct 2025 08:23:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780492 ITAT held that the wholly-owned offshore company is a separate corporate entity and cannot be treated as the assessee's proprietary concern, allowing the taxpayer's stance. The Tribunal upheld that electrical installations form part of plant and machinery, permitting depreciation at 15% instead of 10%. A payment to settle a patent dispute was held to be a compensatory commercial expenditure deductible under Section 37; the disallowance was deleted. Grounds 1 and 2 of the appeal were allowed; the alternative plea under Section 28 was rendered academic. Case-Laws Income Tax Wed, 01 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780492