https://www.taxtmi.com/caselaws?id=443361 The court upheld the treatment of royalty payments as revenue expenditure, allowing the assessee a 100% deduction. It ruled that the royalty payment for business improvement did not involve transfer of ownership, qualifying it as revenue expenditure. The court also held that Rule 8D could not be applied retrospectively, benefiting the assessee and leading to the dismissal of Revenue's appeals. Additionally, the court favored the assessee regarding expenditure attributable to income not included in total income, resulting in the dismissal of the Tax case Appeals filed by the Revenue without costs. en-us Mon, 04 Sep 2023 00:00:00 +0530 Fri, 22 Sep 2023 08:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443361 The court upheld the treatment of royalty payments as revenue expenditure, allowing the assessee a 100% deduction. It ruled that the royalty payment for business improvement did not involve transfer of ownership, qualifying it as revenue expenditure. The court also held that Rule 8D could not be applied retrospectively, benefiting the assessee and leading to the dismissal of Revenue's appeals. Additionally, the court favored the assessee regarding expenditure attributable to income not included in total income, resulting in the dismissal of the Tax case Appeals filed by the Revenue without costs. Case-Laws Income Tax Mon, 04 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443361