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    <title>2025 (1) TMI 1692 - ITAT, AHMEDABAD</title>
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    <description>In rectification proceedings, the ITAT held that its direction on a remanded issue required clarification and modified the operative paragraph to mandate that the AO decide the matter in light of binding SC orders; the order stood modified accordingly. On training expenses, it found no mistake apparent from the record because the order had already restored the issue to the AO for fresh examination, justifying disposal of the Department&#039;s ground &quot;for statistical purposes&quot;; the rectification request was dismissed on this issue. On depreciation for &quot;oil field equipment,&quot; it accepted that the earlier order had not properly carried through the finding of eligibility at 60% and modified the relevant paragraph to allow the claim in line with the tribunal&#039;s direction for an earlier year; relief was granted. On additional depreciation under s. 32(1)(iia), it found non-adjudication and recalled the order limited to hearing that issue. On DTAA benefit and proof of tax residency, it held the rectification plea sought impermissible review, and rejected it.</description>
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    <pubDate>Fri, 24 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (1) TMI 1692 - ITAT, AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=465412</link>
      <description>In rectification proceedings, the ITAT held that its direction on a remanded issue required clarification and modified the operative paragraph to mandate that the AO decide the matter in light of binding SC orders; the order stood modified accordingly. On training expenses, it found no mistake apparent from the record because the order had already restored the issue to the AO for fresh examination, justifying disposal of the Department&#039;s ground &quot;for statistical purposes&quot;; the rectification request was dismissed on this issue. On depreciation for &quot;oil field equipment,&quot; it accepted that the earlier order had not properly carried through the finding of eligibility at 60% and modified the relevant paragraph to allow the claim in line with the tribunal&#039;s direction for an earlier year; relief was granted. On additional depreciation under s. 32(1)(iia), it found non-adjudication and recalled the order limited to hearing that issue. On DTAA benefit and proof of tax residency, it held the rectification plea sought impermissible review, and rejected it.</description>
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      <pubDate>Fri, 24 Jan 2025 00:00:00 +0530</pubDate>
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