Revenue expenditure and DTAA fixed base test: franchise fees upheld, while TDS issue was remanded for verification.

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....Franchise fee paid to secure participation rights in the Indian Premier League was treated as revenue expenditure, as the Tribunal followed coordinate bench decisions in the assessee's own earlier years and found no distinguishing feature or reversal of those rulings. The alternative depreciation claim was therefore academic. On payments to a New Zealand resident talent scout, the Tribunal found the arrangement prima facie consistent with independent personal services under Article 14 of the India-New Zealand DTAA and noted that the 183-day condition was satisfied, but remanded the matter for limited verification of whether the consultant had a fixed base in India. If Article 14 conditions are met, no TDS liability arises.....