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    <description>The appeal regarding the disallowance of royalty payments was allowed, treating the payments as revenue expenditure. However, the appeal concerning the disallowance of capital work-in-progress written off was only partly allowed, with the specific ground being dismissed. The Tribunal concluded that the royalty payments, based on a percentage of sales, should be considered as business expenditure, while the capital work-in-progress written off for setting up a new business was deemed a capital expenditure.</description>
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      <description>The appeal regarding the disallowance of royalty payments was allowed, treating the payments as revenue expenditure. However, the appeal concerning the disallowance of capital work-in-progress written off was only partly allowed, with the specific ground being dismissed. The Tribunal concluded that the royalty payments, based on a percentage of sales, should be considered as business expenditure, while the capital work-in-progress written off for setting up a new business was deemed a capital expenditure.</description>
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