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    <title>2017 (5) TMI 708 - ITAT DELHI</title>
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    <description>Expenditure incurred after a business is set up, even before commercial commencement, is allowable as revenue expenditure where it is not capital in nature, and deferred revenue items such as salaries, staff welfare and related charges were therefore deductible. Professional charges claimed in the profit and loss account were also held to be revenue in character because the assessee had already capitalised or deferred the balance and the disputed amount related to business operations. Payments for IPLC, bandwidth and connectivity services to non-residents were neither royalty nor fees for technical services, as there was no use of equipment by the assessee, no human intervention in the service, and no making available of technical knowledge; accordingly, no tax deduction at source was required and the disallowance was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=342970</link>
      <description>Expenditure incurred after a business is set up, even before commercial commencement, is allowable as revenue expenditure where it is not capital in nature, and deferred revenue items such as salaries, staff welfare and related charges were therefore deductible. Professional charges claimed in the profit and loss account were also held to be revenue in character because the assessee had already capitalised or deferred the balance and the disputed amount related to business operations. Payments for IPLC, bandwidth and connectivity services to non-residents were neither royalty nor fees for technical services, as there was no use of equipment by the assessee, no human intervention in the service, and no making available of technical knowledge; accordingly, no tax deduction at source was required and the disallowance was deleted.</description>
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