Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Annual IPL franchise fee was treated as revenue expenditure because it only enabled participation for the year and did not create an enduring asset; the Revenue challenge failed. Travel, hospitality and related match-arrangement expenses were sustained as business expenditure, subject only to limited verification of supporting bills. Website development expense was also allowed as revenue in nature. Club membership expenditure used for business meetings and interactions was held allowable under section 37(1). Salary provision under mercantile accounting and bonus paid before the return filing due date were held to be accrued and allowable liabilities, so the disallowance was deleted. The Revenue appeals were dismissed.
Annual IPL franchise fee was treated as revenue expenditure because it only enabled participation for the year and did not create an enduring asset; the Revenue challenge failed. Travel, hospitality and related match-arrangement expenses were sustained as business expenditure, subject only to limited verification of supporting bills. Website development expense was also allowed as revenue in nature. Club membership expenditure used for business meetings and interactions was held allowable under section 37(1). Salary provision under mercantile accounting and bonus paid before the return filing due date were held to be accrued and allowable liabilities, so the disallowance was deleted. The Revenue appeals were dismissed.
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