Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Recurring advertising, publicity and sales-promotion expenditure, including visual printing, promotional activities, website applications, hoardings, radio advertising, event management and sponsorships, constitutes revenue expenditure where it supports business in a competitive market without creating a capital asset or enduring benefit. Consistency in income-tax assessments requires the Revenue not to depart from treatment accepted in earlier and later years, including scrutiny assessments, unless fundamental facts materially change. On those principles, capitalisation of the expenditure was rejected and the corresponding addition deleted; other grounds remained open.
Recurring advertising, publicity and sales-promotion expenditure, including visual printing, promotional activities, website applications, hoardings, radio advertising, event management and sponsorships, constitutes revenue expenditure where it supports business in a competitive market without creating a capital asset or enduring benefit. Consistency in income-tax assessments requires the Revenue not to depart from treatment accepted in earlier and later years, including scrutiny assessments, unless fundamental facts materially change. On those principles, capitalisation of the expenditure was rejected and the corresponding addition deleted; other grounds remained open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
