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ITAT held that the customer acquisition costs incurred routinely are revenue in nature and deductible in the year of accrual, not capitalized, because they are recurring and not of enduring benefit. Porting charges and data-entry charges wereheld revenue expenditure. The subsidy/compensation on handsets, being split between amounts recovered from customers (accepted as revenue receipts) and amounts subsidized by the assessee, could not be characterized as capital expenditure; the Assessing Officer's contradictory treatment undermined Revenue's position. Consequently, the Tribunal allowed the contested expenditures as deductible revenue losses for assessment purposes rather than capitalized/depreciable assets.
ITAT held that the customer acquisition costs incurred routinely are revenue in nature and deductible in the year of accrual, not capitalized, because they are recurring and not of enduring benefit. Porting charges and data-entry charges wereheld revenue expenditure. The subsidy/compensation on handsets, being split between amounts recovered from customers (accepted as revenue receipts) and amounts subsidized by the assessee, could not be characterized as capital expenditure; the Assessing Officer's contradictory treatment undermined Revenue's position. Consequently, the Tribunal allowed the contested expenditures as deductible revenue losses for assessment purposes rather than capitalized/depreciable assets.
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