Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Project assistance received from a development authority for constructing and establishing water infrastructure is characterised by its purpose: assistance for project development is capital in nature, unlike operational assistance, which may be revenue. The note states that the Tribunal treated the assistance as a capital receipt and deleted the corresponding revenue addition, following its consistent prior approach. It also states that excess construction expenditure over capital assistance may be amortised over the concession period as deferred revenue expenditure where consistent with applicable accounting principles and CBDT guidance for infrastructure facilities. The disallowance of amortised project expenditure was deleted; interest and penalty issues were consequential and premature.
Project assistance received from a development authority for constructing and establishing water infrastructure is characterised by its purpose: assistance for project development is capital in nature, unlike operational assistance, which may be revenue. The note states that the Tribunal treated the assistance as a capital receipt and deleted the corresponding revenue addition, following its consistent prior approach. It also states that excess construction expenditure over capital assistance may be amortised over the concession period as deferred revenue expenditure where consistent with applicable accounting principles and CBDT guidance for infrastructure facilities. The disallowance of amortised project expenditure was deleted; interest and penalty issues were consequential and premature.
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