Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
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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