TMI Blog2018 (5) TMI 1166X X X X Extracts X X X X X X X X Extracts X X X X ..... that:- The recipient of the fees did not have permanent establishment in India. This Question is therefore also not considered. Depreciation on Hummer Car - as per revenue car was in the name of the Director and there was no evidence to show that the same was used wholly and exclusively for the purpose of business - Held that:- Case of the assessee was that the payment for purchase of vehicle was made by the Company, though the car was registered in the name of the Director. This Court under similar circumstances in the case of Commissioner of Income-Tax v. Aravali Finlease Limited, reported in [2011 (8) TMI 814 - Gujarat High Court] ruled in favour of the assessee. This question is, therefore, not considered. Questions [A], [B], [C], ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Act in respect of payment of legal professional fees to non resident ? [ D3] Whether the Appellate Tribunal has erred in law and on facts in deleting the addition made under Section 40 [a](i) on account of non deduction of TDS u/s. 195 of the Act in respect of payment of clinical and analytical testing charges to non-resident ? [ E] Whether the Appellate Tribunal has erred in law and on fact by deleting the addition made on account of Product Registration expenditure considering the same as Revenue ? [ F] Whether the Appellate Tribunal has erred in law and on facts by deleting the addition of ₹ 6,92,93,026/= made on account of Trademark Registration Patent Fee considering the same as Revenue expenses d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... st on Loan to Zydus France of ₹ 13,44,042 ? [ D1] Whether the Appellate Tribunal has erred in law and on facts in deleting the addition made under Section 40[a](i) on account of non deduction of TDS u/s.195 of the Act in respect of payment of commission to non-resident ? [ E] Whether the Appellate Tribunal has erred in law and on fact by deleting the addition made on account of Product Registration expenditure considering the same as Revenue ? [ F] Whether the Appellate Tribunal has erred in law and on facts by deleting the addition of ₹ 6,92,93,026/= made on account of Trademark Registration Patent Fee considering the same as Revenue expenses despite of the facts that they are not recurring in natur ..... X X X X Extracts X X X X X X X X Extracts X X X X
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