Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refus...
CKD/SKD air-conditioner components classifiable with finished units by essential character; prior advance ruling extended three years, FTA benefits po...
Scope of judicial review under Article 226: supervisory, not appellate; factual reappraisal barred, challenge dismissed; insolvency professional dutie...
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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