Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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The Appellate Tribunal addressed the disallowance of depreciation claimed on software purchases u/s 40(a)(i)/(ia) due to non-deduction of tax at source. The AO contended that the software purchased were copyrights, hence payments were royalty. However, depreciation is a statutory deduction u/s 32, irrespective of TDS. The Tribunal cited a Supreme Court ruling emphasizing that for a payment to be royalty, there must be a right to use without commercially exploiting intellectual property. The Tribunal allowed the assessee's appeal on this issue. Regarding depreciation on servers/network equipment, the Tribunal relied on precedent and granted depreciation at 60%. The revenue's arguments were rejected.
The Appellate Tribunal addressed the disallowance of depreciation claimed on software purchases u/s 40(a)(i)/(ia) due to non-deduction of tax at source. The AO contended that the software purchased were copyrights, hence payments were royalty. However, depreciation is a statutory deduction u/s 32, irrespective of TDS. The Tribunal cited a Supreme Court ruling emphasizing that for a payment to be royalty, there must be a right to use without commercially exploiting intellectual property. The Tribunal allowed the assessee's appeal on this issue. Regarding depreciation on servers/network equipment, the Tribunal relied on precedent and granted depreciation at 60%. The revenue's arguments were rejected.
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