https://www.taxtmi.com/caselaws?id=465675 The dominant issue was whether royalty paid by the assessee to its holding company for use of the "CRI" trade mark was disallowable under s. 40A(2)(b) or otherwise not deductible on the basis that, post-amalgamation, the assessee itself owned the mark. Relying on its earlier order in the assessee's own case and on the governing royalty agreement, and following the HC's approval of the amalgamation scheme, the Tribunal held that the payment was for permitted use of the brand and constituted revenue expenditure laid out wholly and exclusively for business. Consequently, the royalty was allowable as a deduction and the Revenue's appeal was dismissed, affirming the CIT(A). en-us Fri, 18 Nov 2022 00:00:00 +0530 Sat, 03 Jan 2026 12:11:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465675 The dominant issue was whether royalty paid by the assessee to its holding company for use of the "CRI" trade mark was disallowable under s. 40A(2)(b) or otherwise not deductible on the basis that, post-amalgamation, the assessee itself owned the mark. Relying on its earlier order in the assessee's own case and on the governing royalty agreement, and following the HC's approval of the amalgamation scheme, the Tribunal held that the payment was for permitted use of the brand and constituted revenue expenditure laid out wholly and exclusively for business. Consequently, the royalty was allowable as a deduction and the Revenue's appeal was dismissed, affirming the CIT(A). Case-Laws Income Tax Fri, 18 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465675