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...
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.
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