Depreciation and routine compliance expenses disallowance did not prove inaccurate particulars or misreporting; penalty sustained only on foreign trav...
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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.
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