https://www.taxtmi.com/caselaws?id=59645 A treaty non-discrimination clause could not be used to extend section 80M deduction to a foreign company where the domestic classification turned on residence-linked statutory conditions, not nationality; the deduction claim failed. Licence fees paid for merchant banking membership were treated as revenue expenditure because they were incurred for business operations and did not create an enduring capital asset; the disallowance was deleted. Broken period interest was also held allowable by following binding precedent, so that disallowance was deleted. The appeal therefore succeeded only in part, with relief granted on the expenditure items but not on the section 80M claim. en-us Sat, 28 Feb 2004 00:00:00 +0530 Mon, 24 Jun 2024 13:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59645 A treaty non-discrimination clause could not be used to extend section 80M deduction to a foreign company where the domestic classification turned on residence-linked statutory conditions, not nationality; the deduction claim failed. Licence fees paid for merchant banking membership were treated as revenue expenditure because they were incurred for business operations and did not create an enduring capital asset; the disallowance was deleted. Broken period interest was also held allowable by following binding precedent, so that disallowance was deleted. The appeal therefore succeeded only in part, with relief granted on the expenditure items but not on the section 80M claim. Case-Laws Income Tax Sat, 28 Feb 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59645