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,

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