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India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
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Recurring advertising, publicity and sales-promotion expenditure, including visual printing, promotional activities, website applications, hoardings, radio advertising, event management and sponsorships, constitutes revenue expenditure where it supports business in a competitive market without creating a capital asset or enduring benefit. Consistency in income-tax assessments requires the Revenue not to depart from treatment accepted in earlier and later years, including scrutiny assessments, unless fundamental facts materially change. On those principles, capitalisation of the expenditure was rejected and the corresponding addition deleted; other grounds remained open.
Recurring advertising, publicity and sales-promotion expenditure, including visual printing, promotional activities, website applications, hoardings, radio advertising, event management and sponsorships, constitutes revenue expenditure where it supports business in a competitive market without creating a capital asset or enduring benefit. Consistency in income-tax assessments requires the Revenue not to depart from treatment accepted in earlier and later years, including scrutiny assessments, unless fundamental facts materially change. On those principles, capitalisation of the expenditure was rejected and the corresponding addition deleted; other grounds remained open.
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