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Commissioner Of Income Tax, Delhi vs M/S Woodward Governor India P. Ltd on 8 April, 2009

"So far as depreciation allowance is concerned the position is perhaps a little simpler because it is a recurrent claim. Under the definition contained under section 32 read with section 43(1) and (6) of Income Tax Act, the depreciation as to be allowed on thereof in earlier years, thus, where the cost of assets subsequently goes up because of devaluation, whatever might have been the position in the earlier year, it is always open to the assessee to insist, and for the income tax officer to agree, that the written down value in the year in which the increased liability has arisen should be taken on the basis of the increase cost minus depreciation earlier allowed on the basis of old cost C.I.T. vs. Woodward Governnor India (P) Ltd. (2007) 162 Taxman 60 Delhi, it was held in case where foreign currency is held on revenue accounts. Increase in liability on accounts of fluctuation in rate of foreign exchange prevailing on last day of financial year is not notional or contingent and therefore, can be allowed as deduction in term, of section 6 ITA NOS. 798-802/DEL/2010 & I.T.A NOS. 963, 1931,1267-1269/DEL/2010 37(1). The amendment to section 43A providing that amount by which liability is increased or reduced as a result of change in rate of exchange during any previous year after acquisition of such assets would be taken into account at time of making payment irrespective of method of accounting adopted by assessee is prospective prior to said amendment in the capital account cases where cost of assets has been either paid fully or in part prior to fluctuation in rate of foreign exchange, cost of assets would corresponding be permitted to be reworked for purpose of repayment or depreciation or investment allowance as the case may be with reference to rate prevailing on last days of financial year in which that fluctuation occurs."
Supreme Court of India Cites 41 - Cited by 480 - S H Kapadia - Full Document
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