https://www.taxtmi.com/caselaws?id=175096 The Delhi HC considered whether section 40(ia) of the Income-tax Act applied to testing fees paid to a foreign entity without deduction of tax at source, whether pre-operative expenses were deductible as revenue expenditure, whether expenditure on issue of fully convertible debentures was revenue or capital in nature, and whether the payment constituted "fees for included services" under Article 12 of the India-US DTAA. The Court framed substantial questions of law and reserved judgment, so no final adjudication on any issue was delivered. en-us Mon, 07 May 2012 00:00:00 +0530 Wed, 13 Apr 2016 17:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=175096 The Delhi HC considered whether section 40(ia) of the Income-tax Act applied to testing fees paid to a foreign entity without deduction of tax at source, whether pre-operative expenses were deductible as revenue expenditure, whether expenditure on issue of fully convertible debentures was revenue or capital in nature, and whether the payment constituted "fees for included services" under Article 12 of the India-US DTAA. The Court framed substantial questions of law and reserved judgment, so no final adjudication on any issue was delivered. Case-Laws Income Tax Mon, 07 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=175096