Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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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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