charges and corporate maintenance charges.
9. For that the Commissioner of Income Tax (Appeals) erred in upholding the
(disallowance of the server maintenance charges ... testing and development charges. Ground Nos.11 to
14 are supportive arguments to the server maintenance charges and
testing and development charges raised in Ground
sole
issue that arises for adjudication is whether testing charges as
received by the assessee should be treated as part of turnover and
deduction ... while computing the
deduction, the assessee did not deduct 90% of testing charges for
Rs.66.79 Lacs in terms of 80HHC(4C), Explanation
business expenditure, claimed excess advertisement expenses
also debited consulting charges, interpretation charges, lab testing
charges and reporting charges to the profit & loss account ... disallowed.
(d) The assessee had debited consulting chares, interpretation charges, lab
testing charges and reporting charges to the Profit and Loss account. In
addition
Company
(279 ITR 165), wherein it has been held that model
test charges is taxable as "Fees for Technical
Services" even ... treated the income received by the
assessee towards model and model testing charges which was received outside
India in connection with the offshore supply
after hearing the parties before him.
As regards receipts by way of testing fees ( . 94.33 lacs) and others ( . 47.24
lacs), for the same reason ... relation to the receipts by way of sale of power, crane
charges, testing charges, etc., i.e., after netting identifiable costs incurred in
relation thereto
accepted in the hands
of Bangalore Turf club that the dope test charges are not liable to tax
deduction at source or if the Bangalore ... respect of Dope Testing Charges to the file of the AO for examining
it afresh after affording adequate opportunity of being heard to the
assessee
started its business during the relevant
previous year and incurring of testing charges of Rs.4,85,395/- is conclusive proof thereof.
5. The appellant ... ought to have appreciated the fact that
the trial run of production testing tantamounts to the appellant setting up / commencing its
business during the year
concessional rate charged by DAVP from
Government Department.
(ii) Testing charges if any.
(iii) Legal expenses as per Govt. Rules
including the instructions issued ... supply of equipments on prorata
basis.
(f) 15% on installation, testing & commissioning
of equipments on pro rata basis.
(g) 15% after completion
Agreement for Maintenance, Installation
and Trade Mark giving specification of system installation,
testing and training services. The Assessing Officer asked for
a detailed break ... also
observed that the services to be provided included
installation charges, testing and training for projectionists.
The training was to be provided with regular service
test and
certify its product before it become eligible to export. For that the
company had incurred certain expenditure like registration expenses,
lab testing charges