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...
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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