https://www.taxtmi.com/caselaws?id=789893 Recurring franchise fees for IPL participation were treated as revenue expenditure because earlier coordinate-bench decisions on identical facts had already so held, and no contrary change in facts or reversal was shown; once characterised as revenue, depreciation on the same amount became infructuous. For talent-scouting payments to a New Zealand resident, the engagement was viewed as independent rather than dependent services, with no employer-employee relationship and treaty residence below 183 days, so the payment was prima facie covered by Article 14 of the India-New Zealand DTAA and not fees for technical services. The matter was remanded only to verify the fixed-base condition and related treaty requirements. en-us Fri, 27 Mar 2026 00:00:00 +0530 Thu, 16 Apr 2026 08:34:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789893 Recurring franchise fees for IPL participation were treated as revenue expenditure because earlier coordinate-bench decisions on identical facts had already so held, and no contrary change in facts or reversal was shown; once characterised as revenue, depreciation on the same amount became infructuous. For talent-scouting payments to a New Zealand resident, the engagement was viewed as independent rather than dependent services, with no employer-employee relationship and treaty residence below 183 days, so the payment was prima facie covered by Article 14 of the India-New Zealand DTAA and not fees for technical services. The matter was remanded only to verify the fixed-base condition and related treaty requirements. Case-Laws Income Tax Fri, 27 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789893