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of HC determined key tax adjustment issues involving intra-group services and telecommunications licensing expenses. The court recognized unresolved questions regarding revenue share-based payments and circuit accrual charges. Specifically, the court found no leasing equipment element precluding TDS application under section 1941. The appeal was admitted on two primary legal questions: (1) validity of disallowances related to circuit accrual charges without documentary evidence, and (2) treatment of amortized revenue-share license fees considering the enduring nature of telecom service rights. The matter was scheduled for further hearing, with potential implications for similar telecommunications tax assessment cases.
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