Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Section 80-IA(4) permits deduction for enterprises that only develop infrastructure facilities; development-only enterprises fall within the provision and are eligible for deduction. Whether an assessee is a developer or merely a works contractor depends on the contractual and factual matrix-labels and periodic payments do not automatically disqualify developer status. Relevant factors include allocation of financial, operational and executional risks, engagement in planning/design/execution, and deployment of assets and personnel; on such facts an entity qualifies as a developer. Handing over possession of the completed facility to the government qualifies as a 'transfer' for the provision's purposes, satisfying the transfer requirement.
Section 80-IA(4) permits deduction for enterprises that only develop infrastructure facilities; development-only enterprises fall within the provision and are eligible for deduction. Whether an assessee is a developer or merely a works contractor depends on the contractual and factual matrix-labels and periodic payments do not automatically disqualify developer status. Relevant factors include allocation of financial, operational and executional risks, engagement in planning/design/execution, and deployment of assets and personnel; on such facts an entity qualifies as a developer. Handing over possession of the completed facility to the government qualifies as a 'transfer' for the provision's purposes, satisfying the transfer requirement.
Note: It is a system-generated summary and is for quick reference only.
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