Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
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.