reasons are as under:
'' SATISFACTION NOTE
M/s. Bharat Heavy Electricals Ltd.
A.Y. 1999-00
The case was assessed ... credited simple interest in the accounts, on
credits extended to Andhra Pradesh State Electricity Board (APSEB) in
respect of supplies made
credited simple interest in the accounts, on credits extended to Andhra Pradesh
State Electricity Board (APSEB) in respect of supplies made ... credited simple interest in the accounts, on credits
extended to Andhra Pradesh State Electricity Board (APSEB) in respect of
supplies made
Industries Ltd. and Rs. 2,23,23,329 purchased from Andhra Pradesh State Electricity Board (in short APSEB) on 29th March ... view that the assessee entered into an agreement with Rajasthan State Electricity Board (RSEB) with a collusive motive to reduce the taxability. The issue
by
showing purchase of plant on paper from APSEB and lease back
the same to APSEB ... expenditure towards earning the lease income.
d) Interest on Lease Financing to APSEB:
The total interest on lease interest has been
claimed that the
company had done liaison work with Andhra Pradesh State Electricity
Board for supply of ash handing plant spares. The Board ... rendering help in
procuring order for supply of spares to Andhra Pradesh State Electricity
Board. The payment to the agent was made through banker
should develop the infrastructure
facility as per agreement with the Central Government, State
Government or a local authority. So, entering into a lawful
agreement ... before us, has developed
infrastructure facility as per agreement with Maharashtra
State Government / APSEB. Therefore, merely because, in
the agreement
respect of interest on line of
credit extended to APSEB which was not received.
(Refer to Para No.10 Page ... interest on line of credit extended to APSEB which was not
received. Ld. AR for the assessee contended that this issue
directed
the ld AO to allow deprecation on asset leased to APSEB.
6. With respect to the other parties he confirmed ... parties that could prove that the transactions are
genuine.
7. Accordingly, except APSEB he confirmed the addition with respect to other
M/S Sumitomo Corporation, New Delhi vs Dcit (International Taxation), New ... on 1 July, 2019
develop the infrastructure
facility as per the agreement with the Central Government, State Government
or a Local Authority. So, entering into a lawful agreement ... assessee has developed infrastructure facility as per the agreement with
Maharashtra Government/APSEB, therefore, merely because in the agreement
for development