record the party-wise details of provision created for
software and testing charges. Therefore, it was contended that
the findings ... record party-
wise details of the provision created for software and testing
charges. On perusal of the same, it is clear that the parties
have
Royalty paid TNMM/CUP 2,45,57,629
5. Testing charges paid TNMM 3,07,869
6. Service charges paid TNMM ... same
amongst group companies
based on reasonable
allocation keys.
e. Testing Payment of testing charges to JM Brussels for testing of sample catalysts for
charges
Elisa Plate Expenses 2,984,199
3 Speed Testing Charges
Testing Charges 2,786,931
Seed Certification 1,200 2,788,199
4 RCGM ... Seed (Demo) 145,268
Model Farm/Demo Exp 8,096
Field Test Charges 4,050
Cattle Feed 82,760
Purchase Thread 7,325
Fertilizers
characterising the services renderd by the
said party as technical consultancy charges/testing charges, had observed
that as the assessee had failed to deduct ... erred in upholding disallowance made for Testing Charges of
Rs. 4,67,244/- considering the same as Fees for Technical Services in
respect of payment
this condition the defendant asked the
plaintiff to deposit 'lab testing charges' pertaining to the subject lot auction. It
is stated that this ... obtained from the defendant's testing agencies / laboratories and
accordingly plaintiff under compulsion deposited lab testing charges amount
heads viz. packing charges,
wear and tear charges, facility charges, service charges, delivery and
collection charges, rental charges, repair and testing charges. The
Assessees treat
have been
possible for the assessee to carry on business.
2.3.7.3 The test of enduring benefit alone is not conclusive for treating any
expenditure ... order to test its suitability for marketing, is expenditure of
the nature of revenue. In the absence of these testing charges, the appellant would
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
that assessee has paid a sum of Rs. 222841520/- towards
testing and commissioning charges on which tax should have been
deducted at the rate ... services availed by the assessee of erection, installation,
testing and commissioning charges are covered under the provisions of
section 194C of the Income
heads viz. packing charges,
wear and tear charges, facility charges, service charges, delivery and
collection charges, rental charges, repair and testing charges. The
Assessees treat
