https://www.taxtmi.com/caselaws?id=280664 Section 40(a)(i) disallowance was deleted for payments to non-resident associated enterprises because the non-discrimination clause in the India-Japan DTAA barred the adverse withholding consequence for the Japanese entity, and no permanent establishment was shown for the Thai entity. Royalty and lump sum model fee under the revised technical collaboration agreement were held revenue in nature because they related to improvement and continuation of an existing business. Airfare and travel forming part of technical guidance fee, software-related recurring costs, and sales tax actually paid under protest were also allowed as revenue expenditure or deductible under section 43B. Section 14A disallowance was rejected because no exempt income was earned during the year. en-us Fri, 18 Aug 2017 00:00:00 +0530 Thu, 16 May 2019 06:26:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280664 Section 40(a)(i) disallowance was deleted for payments to non-resident associated enterprises because the non-discrimination clause in the India-Japan DTAA barred the adverse withholding consequence for the Japanese entity, and no permanent establishment was shown for the Thai entity. Royalty and lump sum model fee under the revised technical collaboration agreement were held revenue in nature because they related to improvement and continuation of an existing business. Airfare and travel forming part of technical guidance fee, software-related recurring costs, and sales tax actually paid under protest were also allowed as revenue expenditure or deductible under section 43B. Section 14A disallowance was rejected because no exempt income was earned during the year. Case-Laws Income Tax Fri, 18 Aug 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280664