Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Proceeds of crime and property equivalent in value: failure to explain lawful source sustains attachment; lack of required notice can vitiate confirma...
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Concessionaire rights acquired under a DBFOT highway agreement were treated as depreciable intangible assets. The Tribunal held that the assessee had, at its own cost, obtained an exclusive licence and authority to operate and maintain the project highway and receive annuity during the concession period, and that this right fell within section 32(1)(ii) as a valuable business or commercial right. Depreciation was allowed on the opening written down value of the intangible asset for the years in appeal. The alternative claim for amortisation was rendered infructuous, and the remaining grounds were treated as academic or left open.
Concessionaire rights acquired under a DBFOT highway agreement were treated as depreciable intangible assets. The Tribunal held that the assessee had, at its own cost, obtained an exclusive licence and authority to operate and maintain the project highway and receive annuity during the concession period, and that this right fell within section 32(1)(ii) as a valuable business or commercial right. Depreciation was allowed on the opening written down value of the intangible asset for the years in appeal. The alternative claim for amortisation was rendered infructuous, and the remaining grounds were treated as academic or left open.
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