Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Recurring annual maintenance charges for optical fibre network usage were treated as revenue expenditure, while upfront connectivity fees were to be amortised on a straight-line basis over the relevant 15-year contractual term, subject to agreement-wise verification. For exempt-income disallowance, own funds in excess of investments and use of borrowed funds for business supported denial of interest disallowance; administrative disallowance was confined to investments yielding exempt income and capped by exempt income earned. The text also notes that broadband network acquisition rights, goodwill arising on amalgamation, and non-compete fee can qualify as depreciable intangible assets, and that appellate authorities may entertain additional claims when facts are already on record.
Recurring annual maintenance charges for optical fibre network usage were treated as revenue expenditure, while upfront connectivity fees were to be amortised on a straight-line basis over the relevant 15-year contractual term, subject to agreement-wise verification. For exempt-income disallowance, own funds in excess of investments and use of borrowed funds for business supported denial of interest disallowance; administrative disallowance was confined to investments yielding exempt income and capped by exempt income earned. The text also notes that broadband network acquisition rights, goodwill arising on amalgamation, and non-compete fee can qualify as depreciable intangible assets, and that appellate authorities may entertain additional claims when facts are already on record.
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