https://www.taxtmi.com/caselaws?id=213612 Testing and certification charges paid to a non-resident were treated as fees for technical services; the section 9(1)(vii)(b) exception was held inapplicable because the source of income from the export activity was in India, though the treaty issue under Article 12 was left for reconsideration and the section 40(a)(ia) consequence was remitted. Pre-operative expenditure for an expansion unit was held revenue expenditure where the facts showed an integrated existing business with common management, interlacing of funds, and interdependence. Expenditure incurred for issue of fully convertible debentures was also held revenue in nature, since the character of borrowing-related issue costs did not change merely because conversion into equity was contemplated later. en-us Mon, 21 May 2012 00:00:00 +0530 Tue, 20 Jan 2026 17:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213612 Testing and certification charges paid to a non-resident were treated as fees for technical services; the section 9(1)(vii)(b) exception was held inapplicable because the source of income from the export activity was in India, though the treaty issue under Article 12 was left for reconsideration and the section 40(a)(ia) consequence was remitted. Pre-operative expenditure for an expansion unit was held revenue expenditure where the facts showed an integrated existing business with common management, interlacing of funds, and interdependence. Expenditure incurred for issue of fully convertible debentures was also held revenue in nature, since the character of borrowing-related issue costs did not change merely because conversion into equity was contemplated later. Case-Laws Income Tax Mon, 21 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213612