Royalties treated as revenue expense, fully deductible; bad debt also allowed. Capital expenditure test clarified.

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....Royalty payments treated as revenue expenditure, deductible in full; capital expenditure treatment rejected. Bad debt deduction allowed u/s 28, following Supreme Court precedent in Shriram Chits case; Revenue appeal rejected. Division Bench judgment of same Court cited, clarifying expenditure to acquire intangible asset not automatically capital expenditure; enduring nature of benefit key consideration. Appellate orders deleting disallowances upheld by High Court.....