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Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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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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