Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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