https://www.taxtmi.com/highlights?id=99049 Where liability to incur construction expenditure had already accrued under the business transaction, the Court applied the mercantile system and the Calcutta Company principle to allow deduction of the estimated expense on accrual basis; the concurrent finding permitting the construction deduction was upheld. In the sale-and-lease-back arrangement involving cinematographic rights, title had passed to the assessee and the vendor thereafter remained only as lessee; mere tax-saving motive, unsupported by material, did not make the transaction a colourable device. Depreciation on the films was therefore allowed, and the Revenue failed on both issues. en-us Wed, 22 Apr 2026 08:47:19 +0530 Wed, 22 Apr 2026 08:47:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99049 Where liability to incur construction expenditure had already accrued under the business transaction, the Court applied the mercantile system and the Calcutta Company principle to allow deduction of the estimated expense on accrual basis; the concurrent finding permitting the construction deduction was upheld. In the sale-and-lease-back arrangement involving cinematographic rights, title had passed to the assessee and the vendor thereafter remained only as lessee; mere tax-saving motive, unsupported by material, did not make the transaction a colourable device. Depreciation on the films was therefore allowed, and the Revenue failed on both issues. Highlights Income Tax Wed, 22 Apr 2026 08:47:19 +0530 https://www.taxtmi.com/highlights?id=99049