https://www.taxtmi.com/circulars?id=7309 The Central Board of Direct Taxes withdraws Instruction No. 1829 because it has been misapplied beyond its original consortium-based turnkey power project context; taxpayers have restructured and split contracts, loaded profits into offshore supply components, and resisted apportionment by reference to functions, risks and assets, so the instruction is withdrawn with immediate effect while preserving the Department's ability to argue in appeals that the instruction did not apply to particular facts. en-us Mon, 20 Jul 2009 00:00:00 +0530 Fri, 31 Jul 2009 09:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=7309 The Central Board of Direct Taxes withdraws Instruction No. 1829 because it has been misapplied beyond its original consortium-based turnkey power project context; taxpayers have restructured and split contracts, loaded profits into offshore supply components, and resisted apportionment by reference to functions, risks and assets, so the instruction is withdrawn with immediate effect while preserving the Department's ability to argue in appeals that the instruction did not apply to particular facts. Circulars Income Tax Mon, 20 Jul 2009 00:00:00 +0530 https://www.taxtmi.com/circulars?id=7309