https://www.taxtmi.com/caselaws?id=122789 Advertisement and sales promotion outlays for brand promotion in an existing cellular business were held revenue in nature because no capital asset or enduring capital advantage was created, and the disallowance was deleted. Expenditure on application software, software rentals and related licences was also treated as revenue because it supported efficient business operations and did not bring a capital asset into existence. Composite management service charges under technical and management agreements required apportionment: the portion linked to setting up the business and acquiring know-how or licence rights was capital, while the balance for operational assistance was revenue. The final result was partial relief only on the apportionment issue. en-us Fri, 09 Oct 2009 00:00:00 +0530 Sat, 07 Oct 2023 12:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122789 Advertisement and sales promotion outlays for brand promotion in an existing cellular business were held revenue in nature because no capital asset or enduring capital advantage was created, and the disallowance was deleted. Expenditure on application software, software rentals and related licences was also treated as revenue because it supported efficient business operations and did not bring a capital asset into existence. Composite management service charges under technical and management agreements required apportionment: the portion linked to setting up the business and acquiring know-how or licence rights was capital, while the balance for operational assistance was revenue. The final result was partial relief only on the apportionment issue. Case-Laws Income Tax Fri, 09 Oct 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122789