https://www.taxtmi.com/caselaws?id=235313 Depreciation on financial leased assets was upheld because the lease arrangement was treated as revenue-neutral under CBDT Circular No. 2 of 2001, and the lessee's use of the asset or registration in the lessee's name did not by itself justify denial of the claim. Guarantee commission paid to the holding company was also held outside article 11 of the India-U.S. treaty because "debt-claims" was confined to loan-like obligations and did not extend to such commission. Both Revenue challenges failed, and the appeals were dismissed. en-us Wed, 20 Apr 2011 00:00:00 +0530 Fri, 19 Jul 2013 07:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=235313 Depreciation on financial leased assets was upheld because the lease arrangement was treated as revenue-neutral under CBDT Circular No. 2 of 2001, and the lessee's use of the asset or registration in the lessee's name did not by itself justify denial of the claim. Guarantee commission paid to the holding company was also held outside article 11 of the India-U.S. treaty because "debt-claims" was confined to loan-like obligations and did not extend to such commission. Both Revenue challenges failed, and the appeals were dismissed. Case-Laws Income Tax Wed, 20 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=235313