Disallowance of pro-rata premium on Foreign Currency Convertible ...

Tonnage Tax Scheme: No FCCB premium deduction allowed. Expenditure against tonnage income prohibited. Free funds argument rejected. 60% depreciation on UPS.

Case Laws Income Tax

August 7, 2024

Disallowance of pro-rata premium on Foreign Currency Convertible Bonds (FCCB) claimed as expenditure by assessee under Tonnage Tax Scheme. Law prohibits deduction of any expenditure against Tonnage income once specified provisions accepted. Assessee's argument of availability of free funds rejected as not raised before lower authority. Depreciation on UPS allowed at 60% rate as per Ushodaya case, overruling 15% rate. ITAT refers to Appellate Tribunal.

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Disallowance of pro-rata premium on Foreign Currency Convertible ...

Tonnage Tax Scheme: No FCCB premium deduction allowed. Expenditure against tonnage income prohibited. Free funds argument rejected. 60% depreciation on UPS.

Case Laws Income Tax

August 7, 2024

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