Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Software licence, database support and related IT expenditure was held to be revenue in nature because it secured only a limited right to use software, with no acquisition of proprietary or copyright rights and no independent enduring asset. Applying the principle from Engineering Analysis, the Tribunal treated the payments as facilitating day-to-day business operations and upheld deletion of the disallowance. On year-end provisions, the Tribunal held that repeated disallowance of the same item would create impermissible double disallowance; the matter was restored for limited verification of prior disallowance or tax deduction and corresponding relief to prevent duplication.
Software licence, database support and related IT expenditure was held to be revenue in nature because it secured only a limited right to use software, with no acquisition of proprietary or copyright rights and no independent enduring asset. Applying the principle from Engineering Analysis, the Tribunal treated the payments as facilitating day-to-day business operations and upheld deletion of the disallowance. On year-end provisions, the Tribunal held that repeated disallowance of the same item would create impermissible double disallowance; the matter was restored for limited verification of prior disallowance or tax deduction and corresponding relief to prevent duplication.
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