Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
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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