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    <title>Revenue expenditure and DTAA fixed base test: franchise fees upheld, while TDS issue was remanded for verification.</title>
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    <description>Franchise fee paid to secure participation rights in the Indian Premier League was treated as revenue expenditure, as the Tribunal followed coordinate bench decisions in the assessee&#039;s own earlier years and found no distinguishing feature or reversal of those rulings. The alternative depreciation claim was therefore academic. On payments to a New Zealand resident talent scout, the Tribunal found the arrangement prima facie consistent with independent personal services under Article 14 of the India-New Zealand DTAA and noted that the 183-day condition was satisfied, but remanded the matter for limited verification of whether the consultant had a fixed base in India. If Article 14 conditions are met, no TDS liability arises.</description>
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    <pubDate>Thu, 16 Apr 2026 08:34:09 +0530</pubDate>
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      <title>Revenue expenditure and DTAA fixed base test: franchise fees upheld, while TDS issue was remanded for verification.</title>
      <link>https://www.taxtmi.com/highlights?id=98847</link>
      <description>Franchise fee paid to secure participation rights in the Indian Premier League was treated as revenue expenditure, as the Tribunal followed coordinate bench decisions in the assessee&#039;s own earlier years and found no distinguishing feature or reversal of those rulings. The alternative depreciation claim was therefore academic. On payments to a New Zealand resident talent scout, the Tribunal found the arrangement prima facie consistent with independent personal services under Article 14 of the India-New Zealand DTAA and noted that the 183-day condition was satisfied, but remanded the matter for limited verification of whether the consultant had a fixed base in India. If Article 14 conditions are met, no TDS liability arises.</description>
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      <pubDate>Thu, 16 Apr 2026 08:34:09 +0530</pubDate>
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