https://www.taxtmi.com/caselaws?id=394905 The article discusses multiple tax treatment issues arising from business restructuring and asset transfers, including the revenue character of software licence costs, interest and prepayment charges, professional fees for integration services, consultant payments, stock and receivable write-offs, and losses on closure of divisions. It also addresses MODVAT adjustment under section 145A, exclusion of certain receipts under clause (baa) of Explanation to section 80HHC, capital gains computation on partial transfer of a property with land/building bifurcation and fair market value adoption, depreciation claims, and disallowance for foreign professional fees under section 40(a)(i). The central theme is that expenditure incurred for commercial expediency and business efficiency is generally deductible as revenue expenditure unless it creates a capital asset or enduring capital advantage. en-us Thu, 20 Feb 2020 00:00:00 +0530 Tue, 28 Apr 2020 12:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=394905 The article discusses multiple tax treatment issues arising from business restructuring and asset transfers, including the revenue character of software licence costs, interest and prepayment charges, professional fees for integration services, consultant payments, stock and receivable write-offs, and losses on closure of divisions. It also addresses MODVAT adjustment under section 145A, exclusion of certain receipts under clause (baa) of Explanation to section 80HHC, capital gains computation on partial transfer of a property with land/building bifurcation and fair market value adoption, depreciation claims, and disallowance for foreign professional fees under section 40(a)(i). The central theme is that expenditure incurred for commercial expediency and business efficiency is generally deductible as revenue expenditure unless it creates a capital asset or enduring capital advantage. Case-Laws Income Tax Thu, 20 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=394905