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    <title>2026 (5) TMI 96 - ITAT DELHI</title>
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    <description>Ad hoc capitalisation of advertisement, publicity and sales promotion was rejected because no tangible material showed creation of a capital asset; such recurring business outgoings remained revenue expenditure. A TDS mismatch in Form 26AS did not justify an addition where income was recognised proportionately under the mercantile method, since TDS credit follows the year in which the corresponding income is assessable under section 199 read with Rule 37BA. Interest under section 244A was also not taxable in the relevant year because the refund and consequential interest had not finally crystallized and no enforceable right to receive had arisen. The Revenue&#039;s appeal failed and the deletions were maintained.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790894</link>
      <description>Ad hoc capitalisation of advertisement, publicity and sales promotion was rejected because no tangible material showed creation of a capital asset; such recurring business outgoings remained revenue expenditure. A TDS mismatch in Form 26AS did not justify an addition where income was recognised proportionately under the mercantile method, since TDS credit follows the year in which the corresponding income is assessable under section 199 read with Rule 37BA. Interest under section 244A was also not taxable in the relevant year because the refund and consequential interest had not finally crystallized and no enforceable right to receive had arisen. The Revenue&#039;s appeal failed and the deletions were maintained.</description>
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