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    Limitation for customs demand confined recovery period, while suppression findings revived penalty and required stock-based recomputation.
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      Telecom tax treatment was addressed across depreciation,...

      Telecom tax treatment under depreciation, 80-IA, 14A and transfer pricing was clarified across multiple receipt and expense issues.

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      Income TaxJune 25, 2026Case LawsAT
      Telecom tax treatment was addressed across depreciation, deduction and transfer pricing issues: spectrum rights were treated as intangible assets eligible for depreciation, while annual licence fees were capital in nature and had to be amortised under section 35ABB; recurring spectrum usage charges paid to WPC were revenue expenditure. The note also records that section 14A disallowance was not permissible without exempt income, roaming charges were not treated as fees for technical services, and ECB interest with upfront fee had to be benchmarked on proper comparables and approved all-in-cost. For section 80-IA, telecom-related receipts including scrap sales and allied operational income were considered eligible, prepaid revenue accrued on service or voucher expiry, and passive infrastructure transferred under a court-approved scheme was treated as a gift.

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      ActsIncome Tax