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    <title>2022 (5) TMI 1704 - ITAT BANGALORE</title>
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    <description>An additional ground challenging Dividend Distribution Tax by reference to treaty rate was not admitted because that dispute did not arise from the regular assessment order and belonged to a separate appellate stream. The Tribunal held that an aviation fuel farm, feeder lines and hydrant system formed part of airport infrastructure, that an airport operator could satisfy the statutory agreement requirement, and that the BOOT-based project was not a mere works contract; deduction under section 80-IA was therefore allowed and required recomputation under section 80-IA(5). Interest paid under a hedge swap linked to business borrowing for the project was treated as financing cost incurred for business purposes and allowed as a revenue deduction.</description>
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    <pubDate>Fri, 20 May 2022 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=466964</link>
      <description>An additional ground challenging Dividend Distribution Tax by reference to treaty rate was not admitted because that dispute did not arise from the regular assessment order and belonged to a separate appellate stream. The Tribunal held that an aviation fuel farm, feeder lines and hydrant system formed part of airport infrastructure, that an airport operator could satisfy the statutory agreement requirement, and that the BOOT-based project was not a mere works contract; deduction under section 80-IA was therefore allowed and required recomputation under section 80-IA(5). Interest paid under a hedge swap linked to business borrowing for the project was treated as financing cost incurred for business purposes and allowed as a revenue deduction.</description>
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