https://www.taxtmi.com/caselaws?id=212934 Expenditure on upkeep, servicing, consumables, spares and minor repairs to drilling rigs and auxiliary equipment is treated as revenue where the equipment is already installed, operations have commenced, and no new asset or enduring capital benefit is created. For a non-resident's permanent establishment, head office expenditure must be considered in light of both section 44C and the applicable treaty, with common administrative allocations requiring verification and arm's length support. A receivable is not to be taxed again in the year in dispute where it was actually received and recognised in a subsequent year, subject to verification of the underlying facts. en-us Mon, 23 Apr 2012 00:00:00 +0530 Wed, 16 May 2012 19:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212934 Expenditure on upkeep, servicing, consumables, spares and minor repairs to drilling rigs and auxiliary equipment is treated as revenue where the equipment is already installed, operations have commenced, and no new asset or enduring capital benefit is created. For a non-resident's permanent establishment, head office expenditure must be considered in light of both section 44C and the applicable treaty, with common administrative allocations requiring verification and arm's length support. A receivable is not to be taxed again in the year in dispute where it was actually received and recognised in a subsequent year, subject to verification of the underlying facts. Case-Laws Income Tax Mon, 23 Apr 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212934