Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
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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