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...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Nature of expenses - Relaunch expenses - deferred revenue expenditure claimed to the extent of 1/3rd in each of the year -The tribunal disagreed with the AO's categorization of the relaunch expenses as capital expenditure. It recognized these expenses as revenue in nature, incurred during the ordinary course of business for rebranding and promotional activities. The tribunal referenced several precedents where similar expenses were treated as revenue expenses, thereby allowing the appeal on this point.
Nature of expenses - Relaunch expenses - deferred revenue expenditure claimed to the extent of 1/3rd in each of the year -The tribunal disagreed with the AO's categorization of the relaunch expenses as capital expenditure. It recognized these expenses as revenue in nature, incurred during the ordinary course of business for rebranding and promotional activities. The tribunal referenced several precedents where similar expenses were treated as revenue expenses, thereby allowing the appeal on this point.
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