https://www.taxtmi.com/caselaws?id=795603 Marketing and advertising expenditure to promote and expand an existing online streaming platform is revenue expenditure under Section 37(1) where it creates no asset or advantage in the capital field; Section 35D amortisation does not apply. Payments for end-user access to standard subscription software and cloud services are not royalty where the user receives no right to reproduce, exploit, or otherwise use underlying copyright or intellectual property. As no income is chargeable to tax in India, no withholding obligation arises under Section 195 and disallowance under Section 40(a)(i) is not sustainable. en-us Wed, 15 Jul 2026 00:00:00 +0530 Fri, 24 Jul 2026 08:36:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795603 Marketing and advertising expenditure to promote and expand an existing online streaming platform is revenue expenditure under Section 37(1) where it creates no asset or advantage in the capital field; Section 35D amortisation does not apply. Payments for end-user access to standard subscription software and cloud services are not royalty where the user receives no right to reproduce, exploit, or otherwise use underlying copyright or intellectual property. As no income is chargeable to tax in India, no withholding obligation arises under Section 195 and disallowance under Section 40(a)(i) is not sustainable. Case-Laws Income Tax Wed, 15 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795603