https://www.taxtmi.com/caselaws?id=272305 Composite agreements for a nuclear power project must be read holistically when characterising payments to a foreign collaborator; on that footing, the receipts were treated as project-related under section 44BBB rather than as fees for technical services or royalty. Where the material facts remained unchanged across assessment years, consistency required the Revenue to follow the view already accepted in earlier years, absent any distinguishing feature or new factual basis. The earlier approach was therefore followed and the contrary position rejected. en-us Fri, 12 Feb 2016 00:00:00 +0530 Fri, 04 Mar 2016 11:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=272305 Composite agreements for a nuclear power project must be read holistically when characterising payments to a foreign collaborator; on that footing, the receipts were treated as project-related under section 44BBB rather than as fees for technical services or royalty. Where the material facts remained unchanged across assessment years, consistency required the Revenue to follow the view already accepted in earlier years, absent any distinguishing feature or new factual basis. The earlier approach was therefore followed and the contrary position rejected. Case-Laws Income Tax Fri, 12 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=272305