Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Marketing and advertising expenditure incurred to promote an already operational online streaming platform is described as revenue expenditure where it supports business expansion and user engagement without creating a new capital asset or advantage in the capital field. The notes state that the enduring-benefit test is not conclusive and that such expenditure cannot be treated as preliminary expenditure for amortisation. They also state that end-user payments to non-residents for subscription-based software and cloud services are not royalty absent a right to exploit underlying copyright or intellectual property; accordingly, no tax deduction at source obligation arises and related disallowance is not warranted.
Marketing and advertising expenditure incurred to promote an already operational online streaming platform is described as revenue expenditure where it supports business expansion and user engagement without creating a new capital asset or advantage in the capital field. The notes state that the enduring-benefit test is not conclusive and that such expenditure cannot be treated as preliminary expenditure for amortisation. They also state that end-user payments to non-residents for subscription-based software and cloud services are not royalty absent a right to exploit underlying copyright or intellectual property; accordingly, no tax deduction at source obligation arises and related disallowance is not warranted.
Note: It is a system-generated summary and is for quick reference only.
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