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    <title>2013 (7) TMI 729 - ITAT MUMBAI</title>
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    <description>Royalty paid as a percentage of sales for continuous use of technical know-how and related rights was treated as revenue expenditure, as a linked payment does not create an enduring capital advantage; the disallowance was deleted. Partial disallowance of employees&#039; club, hotel, lodging and related credit-card expenses was sustained because the assessee failed to prove the full business nexus. For exempt dividend income, rule 8D was not applicable for the year, but expenditure attributable to such income still had to be disallowed on a reasonable basis, so the matter was restored for fresh determination after giving the assessee an opportunity.</description>
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      <description>Royalty paid as a percentage of sales for continuous use of technical know-how and related rights was treated as revenue expenditure, as a linked payment does not create an enduring capital advantage; the disallowance was deleted. Partial disallowance of employees&#039; club, hotel, lodging and related credit-card expenses was sustained because the assessee failed to prove the full business nexus. For exempt dividend income, rule 8D was not applicable for the year, but expenditure attributable to such income still had to be disallowed on a reasonable basis, so the matter was restored for fresh determination after giving the assessee an opportunity.</description>
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