Payment of Upfront Fees by DIAL held to be Revenue Expenditure

Advocate Akhilesh Kumar Sah Payment of Upfront Fees by Delhi International Airport Limited  (DIAL) Held To Be Revenue Expenditure Recently, in ACIT vs. Delhi International Airport Pvt. Ltd. [ ITA No. 2720/DEL/2011, decided on 14.12.2017] Revenue had challenged the finding of the CIT (A) in treating the “Upfront fees” of Rs. 150,00,00,000/- as revenue expenditure instead of capital expenditure treated by the AO. Briefly, in the above-mentioned appeals, pursuant to “Operation, Management and Development Agreement” (hereinafter referred to as OMDA), a lease deed was sim...