BOT annuity rights are not depreciable intangible assets, while project-cost amortisation may follow provisional completion certification.

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....Rights to receive annuity under a BOT road concession are treated as mechanisms for recouping project costs, comparable to toll-collection rights, rather than distinct intangible assets. The notes state that the broader contractual obligations, exclusive licence and annuity-based compensation do not create a licence, franchise or similar business or commercial right eligible for depreciation; depreciation on the annuity right was therefore disallowed. Capitalised road-project expenditure may, however, be amortised when a Provisional Completion Certificate deems the project complete and open to traffic under the concession agreement and applicable CBDT circular. Accordingly, amortisation was sustained despite the disallowance of depreciation.....