Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Telecommunication-business tax treatment covers the timing and scope of deductions, revenue expenditure and transfer-pricing adjustments. Profits eligible for the telecommunication undertaking deduction include receipts with an integral business nexus, while Service from India Scheme incentives are excluded; the initial deduction year depends on when the claim was actually allowed. Annual telecom licence fees are subject to statutory amortisation rather than revenue deduction, whereas spectrum-use charges, ordinary advertising costs, subscriber-fraud losses and certain asset-restoration costs may be revenue expenditure. Automated domestic roaming payments and pre-paid distributor discounts do not require tax deduction at source. Brand-royalty and advertisement, marketing and promotion adjustments cannot rest on commercial-necessity objections or the bright-line test without a demonstrable international transaction.
Telecommunication-business tax treatment covers the timing and scope of deductions, revenue expenditure and transfer-pricing adjustments. Profits eligible for the telecommunication undertaking deduction include receipts with an integral business nexus, while Service from India Scheme incentives are excluded; the initial deduction year depends on when the claim was actually allowed. Annual telecom licence fees are subject to statutory amortisation rather than revenue deduction, whereas spectrum-use charges, ordinary advertising costs, subscriber-fraud losses and certain asset-restoration costs may be revenue expenditure. Automated domestic roaming payments and pre-paid distributor discounts do not require tax deduction at source. Brand-royalty and advertisement, marketing and promotion adjustments cannot rest on commercial-necessity objections or the bright-line test without a demonstrable international transaction.
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