“Section 2(47)(5)”

Customer acquisition costs and advertisement expenditures are treated as revenue expenditures, not deferred expenditures, as there is no general concept of deferred expenditure for such items under Income Tax Law.

Deduction under section 80IA(2A) is available for telecommunication services, including other incomes that form part of the profits and gains of the eligible business. The legislative intent in adopting specific wording for subsection (2A) indicates a conscious departure from previous provisions.

Transfer of a right to receive capital asset is a transfer of a capital asset. The transfer of the right to receive a capital asset is considered a transfer of a capital asset for the purposes of capital gains tax.

Deduction under section 80IA for telecommunication services is allowable in respect of profits of eligible business, not restricted to profits derived from the eligible business. Subsection (2A) of section 80IA is wider in scope than subsection (1).

The levy of interest under Section 234-A of the Income Tax Act is statutory, mandatory, and automatic, meaning it cannot be a question of law that can be raised in appeal. The High Court's jurisdiction under Section 260A is limited to questions of law, and thus, observations on the levy of interest are generally outside its scope.

An assessee is entitled to relief under Section 54F for the purchase of a new residential property if an agreement to sell the old property was executed and the new property was purchased within one year of that agreement, even if the sale deed for the old property was not executed within the prescribed time. Section 54F is a beneficial provision and should be interpreted liberally.