Additional claim for refund of excess dividend distribution tax...

Additional claim for refund of excess dividend distribution tax on dividends paid to a Singapore shareholder at the treaty rate was admitted and remitted to the Assessing Officer for consideration after the Supreme Court larger Bench resolves the underlying issue. Reference to a larger Bench does not, by itself, prevent the Tribunal from following binding jurisdictional High Court precedent, although the merits were left open. Market research and media-measurement expenditure incurred by a media agency was treated as revenue expenditure because client agreements, invoices and the business model established commercial expediency and business nexus; absent contrary material on genuineness, quantum or reasonableness, deletion of disallowance was affirmed.