Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Digital advertising and sales-promotion expenditure on media space, SMS broadcasts, search-engine optimisation, campaign content, marketing videos and social-media strategy is revenue expenditure where it comprises recurring promotional measures, creates no business asset and only improves product promotion through a digital platform. The enduring-benefit test does not make such expenditure capital without an asset or capital-field advantage. Payments for website and mobile-app search services are likewise revenue expenditure where they improve product searches, correct search terms and facilitate sales without creating a capital asset or enduring capital advantage. Disallowances of both categories were deleted; the Revenue's appeals failed and supportive cross-objections became infructuous.
Digital advertising and sales-promotion expenditure on media space, SMS broadcasts, search-engine optimisation, campaign content, marketing videos and social-media strategy is revenue expenditure where it comprises recurring promotional measures, creates no business asset and only improves product promotion through a digital platform. The enduring-benefit test does not make such expenditure capital without an asset or capital-field advantage. Payments for website and mobile-app search services are likewise revenue expenditure where they improve product searches, correct search terms and facilitate sales without creating a capital asset or enduring capital advantage. Disallowances of both categories were deleted; the Revenue's appeals failed and supportive cross-objections became infructuous.
Note: It is a system-generated summary and is for quick reference only.
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