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    <title>2018 (12) TMI 1820 - ITAT MUMBAI</title>
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    <description>Annual franchise consideration securing only season-specific participation rights was treated as revenue expenditure, so depreciation did not arise. Feasibility study expenses and stamp duty were also held to be business outgoings, as they did not create a new asset or enduring advantage. Estimate-based disallowances for airfare, travelling, lodging, boarding, food and nutrition were sent back for verification because they were not supported by proper documentary examination. Sponsorship rights income was sustained in the year under appeal on the assessee&#039;s accounting treatment, with protection against double taxation in a later year if taxed again. The Revenue&#039;s appeal was dismissed as not maintainable because the tax effect fell below the CBDT monetary limit.</description>
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      <description>Annual franchise consideration securing only season-specific participation rights was treated as revenue expenditure, so depreciation did not arise. Feasibility study expenses and stamp duty were also held to be business outgoings, as they did not create a new asset or enduring advantage. Estimate-based disallowances for airfare, travelling, lodging, boarding, food and nutrition were sent back for verification because they were not supported by proper documentary examination. Sponsorship rights income was sustained in the year under appeal on the assessee&#039;s accounting treatment, with protection against double taxation in a later year if taxed again. The Revenue&#039;s appeal was dismissed as not maintainable because the tax effect fell below the CBDT monetary limit.</description>
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