appellant.
5.6. The appellant has stated that the work of BOT projects is
handled by only five divisions of the appellant and the remaining ... divisions do not undertake any work relating to BOT projects.
Therefore, payment to and provision for employees of these five
divisions and the head office
assessee claimed depreciation of Rs.
17,01,00,116/- on BOT Project @ 25% on the opening ... days. He accordingly, computed the allowable amortization of
BOT project for the FY relevant to AY 2013-14 as under:
Opening
units where toll collection takes place should be allocated against
the BOT projects where deduction u/s 80-IA(4) has been claimed
ignoring that ... expenditure, interest cost in respect of BOT assets and
proportionate cost of BOT work in respect of BOT projects. All these
expenses have been considered
construction period.
Further, expenditure incurred by the assessee
on such BOT projects brings to it an enduring
benefit in the form of right to collect ... construction on development of
infrastructure facility of roads/highways under
BOT projects may be amortized and claimed as
allowable business expenditure under
financial
year 2008-09 and 2009-10 from cost of BOT project for computing
deferred revenue expenditure.
6. By the impugned order CIT(A) declined ... directed the AO to consider entire cost of BOT
project of Rs.380,11,68,820/- without reducing grant received
construction
period. Further, expenditure incurred by the assessee on such BOT
projects brings to it an enduring benefit in the form of right to collect ... construction on development of infrastructure facility of roads/highways
under BOT projects may be amortized and claimed as allowable business
expenditure under
maintain a project relating to construction operation and maintenance of
Paradip Port connectivity project under the Build Operate Transfer (BOT)
basis. For this purpose ... initial
cost of development of infrastructure facility of roads highways under
BOT projects in earlier year, the total deduction so claimed for the
Assessment Years
construction period. Further,
expenditure incurred by the assessee on such BOT projects brings to it an
enduring benefit in the form of right to collect ... period. Therefore, analogously, expenditure
incurred on an infrastructure project for development of roads/highways
under BOT agreement may be treated as having been made/incurred
firm was working as a sub
contractor for a BOT (Build Operate & Transfer) project and not as a direct
contractor for the government ... material has been supplied by the
17
Government for the BOT project also give credence to the profits returned by
the assessee.
16.9 Notwithstanding anything
deletion of
interest expenses of Rs.42,77,609/- attributable to BOT projects by the
ld.CIT(A). ITA No.2519/Ahd/2014 is quantum ... with
regard to two additions viz. interest expenses attributable to BOT
projects claimed in regular business of Rs.42,77,609/- and interest
expenditure relating
