Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
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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