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2020 (3) TMI 946 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Assessee undertook to provide sales support services, software development services as a contract software development services provider, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Disallowance of depreciation under section 40 (a) (ia) - HELD THAT:- It is observed that this tribunal in many cases has analysed applicability of section 40(a)(i) of the act for disallowance of depreciation on such capitalised expenditure and has held that no section 40 (a) (i) of the Act, cannot be applied for claim of deduction under section 32 of the Act. However by way of abundant caution we direct Ld.AO to verify the fact whether assets in respect of which expenditure has been capitalised have been used for business of assessee for a period more than 180 days. AO shall verify all these details in light of arguments advanced by Ld.AR - Accordingly this ground raised by assessee stands allowed for statistical purposes.
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