Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Characterisation of software expenditure focused on whether payments were capital or revenue; the payments were held to be recurring annual maintenance, database support and licence renewal costs conferring only annual benefits, with no transfer of ownership, no creation of a software asset or enduring benefit to the assessee's asset base. The assessing officer failed to produce cogent material showing a capital asset arose. Operative effect: the payments were treated as revenue expenditure and allowable under income-tax deductibility principles, leading to deletion of the addition and dismissal of the revenue appeal.
Characterisation of software expenditure focused on whether payments were capital or revenue; the payments were held to be recurring annual maintenance, database support and licence renewal costs conferring only annual benefits, with no transfer of ownership, no creation of a software asset or enduring benefit to the assessee's asset base. The assessing officer failed to produce cogent material showing a capital asset arose. Operative effect: the payments were treated as revenue expenditure and allowable under income-tax deductibility principles, leading to deletion of the addition and dismissal of the revenue appeal.
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