Where assessee provided support services to KFC franchisees in India and to US brand holders of KFC as well, in a systematic and organized way continuously over a period, service income earned was to be treated as business income

IT : Where assessee provided support services to KFC franchisees in India and to US brand holders of KFC as well, in a systematic and organized way continuously over a period, service income earned was to be treated as

business income

IT : Where assessee paid license fee as royalty to UK brand holders for right to use technology and system in business of operating KFC restaurants and pizza huts in India, same was an allowable deduction under section 37(1)

IT : Ever if assessee's wholly owned subsidiary was operating from premises of assessee for carrying out promotion of KFC restaurants and pizza huts owned by assessee, entire amount of overhead expense subsidiary was to be allowed

IT : Food tasting and development expenses incurred by a restaurant was to be treated as revenue expenditure

IT : Provision made for expenses which was based on past experience on mercantile system of accounting was to be allowed

IT : Where assessee reimbursed expenses incurred by its employees on purchase of furnishings as per their grade/level, same was to be held for assessee's business purpose and, hence, depreciation was to be allowed

[2015] 57 taxmann.com 242 (Delhi)

HIGH COURT OF DELHI

Commissioner of Income tax-VI

v.

Yum Restaurants (I) (P.) Ltd.