https://www.taxtmi.com/caselaws?id=760107 The Delhi HC upheld the exclusion of Knowledge Process Outsourcing comparables for an assessee providing IT-enabled services to banks and financial institutions, noting functional dissimilarity in back-end credit card operations. Regarding license fees paid to GECC(USA) for software usage rights, the court held these constituted revenue expenditure deductible under section 37, not capital expenditure. The assessee acquired no ownership rights in the software, with all rights reverting to GECC(USA) upon license termination. The payment provided no enduring benefit, making it revenue in nature rather than acquisition of a capital asset. en-us Fri, 23 Aug 2024 00:00:00 +0530 Tue, 15 Oct 2024 15:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760107 The Delhi HC upheld the exclusion of Knowledge Process Outsourcing comparables for an assessee providing IT-enabled services to banks and financial institutions, noting functional dissimilarity in back-end credit card operations. Regarding license fees paid to GECC(USA) for software usage rights, the court held these constituted revenue expenditure deductible under section 37, not capital expenditure. The assessee acquired no ownership rights in the software, with all rights reverting to GECC(USA) upon license termination. The payment provided no enduring benefit, making it revenue in nature rather than acquisition of a capital asset. Case-Laws Income Tax Fri, 23 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760107