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    <title>2007 (4) TMI 299 - ITAT DELHI-F</title>
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    <description>Royalty and technical fee paid to foreign associated concerns was held not to be disallowable where the payments were backed by agreements, regulatory approvals and evidence of commercial necessity, and no positive material showed diversion of profits or lack of business purpose. UPS attached to a computer was treated as an external power-support device and not an integral part of the computer system, so higher depreciation for computers was not allowable. Advertisement and sales promotion expenditure incurred in India for the assessee&#039;s own business was allowed, as incidental benefit to the foreign brand owner and a bare reference to section 92 did not justify disallowance without material showing absence of business purpose.</description>
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    <pubDate>Mon, 30 Apr 2007 00:00:00 +0530</pubDate>
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      <title>2007 (4) TMI 299 - ITAT DELHI-F</title>
      <link>https://www.taxtmi.com/caselaws?id=65391</link>
      <description>Royalty and technical fee paid to foreign associated concerns was held not to be disallowable where the payments were backed by agreements, regulatory approvals and evidence of commercial necessity, and no positive material showed diversion of profits or lack of business purpose. UPS attached to a computer was treated as an external power-support device and not an integral part of the computer system, so higher depreciation for computers was not allowable. Advertisement and sales promotion expenditure incurred in India for the assessee&#039;s own business was allowed, as incidental benefit to the foreign brand owner and a bare reference to section 92 did not justify disallowance without material showing absence of business purpose.</description>
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