Proportionate interest, unexplained credits and partner remuneration disputed; proofs of fund nexus and lender identity were decisive and disallowance...
Capital gains valuation from stamp assessment versus net consideration for residential reinvestment: deemed stamp value replaced for gains but not for...
The ITAT addressed multiple telecom tax issues, including transfer pricing on royalty and passive infrastructure charges, depreciation on spectrum rights, contractual payments under section 37(1), write-back of liabilities, prepaid distributor discounts, telecom licence fee treatment, lease rentals, WPC royalty, and TDS credit. It deleted the transfer pricing adjustment on royalty and passive infrastructure charges, allowed depreciation and revenue deductions on spectrum-related and contractual payments, treated prepaid distributor discount as outside section 194H, and allowed lease rental and WPC royalty claims as revenue expenditure. It upheld taxation of liabilities written back, directed verification of TDS credit and refund interest, and required amortisation of telecom licence fee under section 35ABB.
The ITAT addressed multiple telecom tax issues, including transfer pricing on royalty and passive infrastructure charges, depreciation on spectrum rights, contractual payments under section 37(1), write-back of liabilities, prepaid distributor discounts, telecom licence fee treatment, lease rentals, WPC royalty, and TDS credit. It deleted the transfer pricing adjustment on royalty and passive infrastructure charges, allowed depreciation and revenue deductions on spectrum-related and contractual payments, treated prepaid distributor discount as outside section 194H, and allowed lease rental and WPC royalty claims as revenue expenditure. It upheld taxation of liabilities written back, directed verification of TDS credit and refund interest, and required amortisation of telecom licence fee under section 35ABB.
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