Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Assessee, an SPV executing a DBOT highway concession, capitalised project costs as intangible assets and claimed depreciation; the AO disallowed depreciation relying on ownership as determinative but allowed amortisation. The Commissioner (Appeals) and the Tribunal applied earlier Tribunal and Special Bench precedents holding that concession assets may attract depreciation despite contractual non ownership, and therefore allowed depreciation. The Tribunal upheld that application of binding precedents and dismissed revenue's appeal for the assessment year, sustaining the Commissioner (Appeals) deletion of the disallowance and permitting depreciation in lieu of the AO's approach.
Assessee, an SPV executing a DBOT highway concession, capitalised project costs as intangible assets and claimed depreciation; the AO disallowed depreciation relying on ownership as determinative but allowed amortisation. The Commissioner (Appeals) and the Tribunal applied earlier Tribunal and Special Bench precedents holding that concession assets may attract depreciation despite contractual non ownership, and therefore allowed depreciation. The Tribunal upheld that application of binding precedents and dismissed revenue's appeal for the assessment year, sustaining the Commissioner (Appeals) deletion of the disallowance and permitting depreciation in lieu of the AO's approach.
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