Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
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Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
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A constituent of joint ventures and consortiums formed to bid for government infrastructure contracts was treated as eligible for deduction under section 80IA(4) because the arrangements were pass-through vehicles, with execution, risk, and profit sharing resting on the members in their agreed proportions. The absence of a direct contract in the assessee's own name did not defeat eligibility where its participation was substantively through the consortium contract. The Tribunal also held that the Explanation to section 80IA(13) excludes only pure works contracts; the assessee, having undertaken design, procurement, construction, commissioning, and operation and maintenance obligations while bearing entrepreneurial and investment risk, was a developer and not a works contractor. Deduction was therefore allowed for both assessment years.
A constituent of joint ventures and consortiums formed to bid for government infrastructure contracts was treated as eligible for deduction under section 80IA(4) because the arrangements were pass-through vehicles, with execution, risk, and profit sharing resting on the members in their agreed proportions. The absence of a direct contract in the assessee's own name did not defeat eligibility where its participation was substantively through the consortium contract. The Tribunal also held that the Explanation to section 80IA(13) excludes only pure works contracts; the assessee, having undertaken design, procurement, construction, commissioning, and operation and maintenance obligations while bearing entrepreneurial and investment risk, was a developer and not a works contractor. Deduction was therefore allowed for both assessment years.
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