Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Website development costs are discussed as qualifying for depreciation at the higher rate applied to computer software, based on earlier decisions. Payment gateway charges paid to banks are characterised as banking-service fees rather than commission or brokerage because the gateway facilitates secure payment settlement without acting as an agent; consequently, tax deduction obligations on commission were not attracted. Advertisement, marketing and publicity expenditure is treated as revenue expenditure where it forms part of the profit-earning process and creates no permanent asset or enduring advantage of decisive character. Ticket-cost reimbursements to an overseas group company are also discussed as not being expenditure claimed by the assessee, supporting deletion of the related tax-deduction disallowance.
Website development costs are discussed as qualifying for depreciation at the higher rate applied to computer software, based on earlier decisions. Payment gateway charges paid to banks are characterised as banking-service fees rather than commission or brokerage because the gateway facilitates secure payment settlement without acting as an agent; consequently, tax deduction obligations on commission were not attracted. Advertisement, marketing and publicity expenditure is treated as revenue expenditure where it forms part of the profit-earning process and creates no permanent asset or enduring advantage of decisive character. Ticket-cost reimbursements to an overseas group company are also discussed as not being expenditure claimed by the assessee, supporting deletion of the related tax-deduction disallowance.
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