Business Continuation Test: SC Confirms Temporary Lull Allows Depreciation & Expense Deductions

Pride Foramer S.A. Vs CIT & Anr. (Supreme Court of India) No Contract ≠ No Business: SC Says Lull Doesn’t Stop Depreciation & Deductions- Commercial Reality Over Technicality – SC Restores Deductions & Set-Off The Appellant, a non-resident French company engaged in offshore drilling, had a 10-year contract with ONGC (1983–1993). After that contract ended, it did not have any drilling contract in India until 1998-99, but during the intervening years it: Maintained continuous correspondence with ONGC, Submitted a bid in 1996 for a new contract (though unsuccessful), Incurred...