Withdrawal of administrative instruction curtails reliance on an outdated tax ruling that enabled offshore profit shifting avoidance. The Central Board of Direct Taxes withdraws Instruction No. 1829 because it has been misapplied beyond its original consortium-based turnkey power project context; taxpayers have restructured and split contracts, loaded profits into offshore supply components, and resisted apportionment by reference to functions, risks and assets, so the instruction is withdrawn with immediate effect while preserving the Department's ability to argue in appeals that the instruction did not apply to particular facts.
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Provisions expressly mentioned in the judgment/order text.
Withdrawal of administrative instruction curtails reliance on an outdated tax ruling that enabled offshore profit shifting avoidance.
The Central Board of Direct Taxes withdraws Instruction No. 1829 because it has been misapplied beyond its original consortium-based turnkey power project context; taxpayers have restructured and split contracts, loaded profits into offshore supply components, and resisted apportionment by reference to functions, risks and assets, so the instruction is withdrawn with immediate effect while preserving the Department's ability to argue in appeals that the instruction did not apply to particular facts.
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