Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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