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2018 (7) TMI 1869 - HC - Income TaxTPA - international transaction - Held that:- This Court and other High Courts which the assessee would like to rely upon. It is open for assessee to rely upon the said ratios. Equally, Revenue will be entitled to defend their stand. Revenue submits as the order of the Tribunal has been set aside, Revenue would raise all pleas and contentions when the appeals are taken up for hearing. It will be open to the Revenue to rely upon judgments and ratios which they feel are in their favour. Counsel for the assessee states that he would have no objection but would contest the contention of the Revenue on merits. Entitlement to depreciation under Section 32 - balance written down value relating to Daru Hera unit, forming part of the block of assets - Held that:- The issue is covered in favour of the assessee and against the Revenue as relying on Sony India Pvt. Ltd. v. CIT. [2017 (1) TMI 1442 - DELHI HIGH COURT] Depreciation at the rate of 60% on UPS, printers and switches - Held that:- The said issue is covered against the Revenue vide decision CIT vs. BSES Yamuna Power Ltd., (2010 (8) TMI 58 - DELHI HIGH COURT). Accordingly, this substantial question of law is answered against the revenue
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