https://www.taxtmi.com/caselaws?id=332178 Royalty and lump sum fee, airfare for technicians, entry tax, and software-related expenditure were treated as revenue items incurred for business purposes rather than capital outlays, so the related additions were deleted. On payments to non-resident associated enterprises, the article states that where the recipients had no permanent establishment in India and the sums were not chargeable to tax, section 195 was not attracted and section 40(a)(i) could not be applied. For one payment, the non-discrimination clause in the Indo-Japan DTAA was applied to prevent a harsher domestic disallowance for non-resident payments. The assessee therefore succeeded on the substantive issues discussed. en-us Wed, 29 Jun 2016 00:00:00 +0530 Mon, 12 Sep 2016 18:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=332178 Royalty and lump sum fee, airfare for technicians, entry tax, and software-related expenditure were treated as revenue items incurred for business purposes rather than capital outlays, so the related additions were deleted. On payments to non-resident associated enterprises, the article states that where the recipients had no permanent establishment in India and the sums were not chargeable to tax, section 195 was not attracted and section 40(a)(i) could not be applied. For one payment, the non-discrimination clause in the Indo-Japan DTAA was applied to prevent a harsher domestic disallowance for non-resident payments. The assessee therefore succeeded on the substantive issues discussed. Case-Laws Income Tax Wed, 29 Jun 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=332178