Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Page of 4811
Press 'Enter' after typing page number.
3801 to 3820 of 96208 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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.
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.
Note: It is a system-generated summary and is for quick reference only.