Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Controlled transactions cannot be used as CUP comparables for brand royalty, so that adjustment was deleted. ECB interest benchmarking accepted RBI approval as a relevant contemporaneous benchmark and deleted the adjustment. AMP expenditure was not treated as an international transaction without tangible evidence of an arrangement. Depreciation on 3G spectrum rights, DoT subscriber verification payments, prepaid distributor discount and IBM hardware lease rentals were allowed, while liabilities written back were sustained and asset restoration cost was allowed as revenue expenditure. Annual licence fee remained capital in nature with only recomputation of amortisation under the telecom licence regime, and WPC royalty charges were also allowed.
Controlled transactions cannot be used as CUP comparables for brand royalty, so that adjustment was deleted. ECB interest benchmarking accepted RBI approval as a relevant contemporaneous benchmark and deleted the adjustment. AMP expenditure was not treated as an international transaction without tangible evidence of an arrangement. Depreciation on 3G spectrum rights, DoT subscriber verification payments, prepaid distributor discount and IBM hardware lease rentals were allowed, while liabilities written back were sustained and asset restoration cost was allowed as revenue expenditure. Annual licence fee remained capital in nature with only recomputation of amortisation under the telecom licence regime, and WPC royalty charges were also allowed.
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