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ITAT applied consistent prior-year treatment to delete the proportionate disallowance under section 80IA for telecom services, holding that the assessee's segmental allocation issue could not justify the adjustment. It also followed the Delhi High Court in the assessee's own case to hold that telecom data transmission payments to non-resident operators were not royalty, so the section 40(a)(i) disallowance for alleged non-deduction of tax was not sustainable under the treaty. The section 40(a)(ia) issue was sent back for verification because the amount had already been disallowed suo motu. On transfer pricing, the Tribunal accepted the limited risk model as consistently applied and sustained adjustment only to the extent of the shortfall in the agreed compensation.
ITAT applied consistent prior-year treatment to delete the proportionate disallowance under section 80IA for telecom services, holding that the assessee's segmental allocation issue could not justify the adjustment. It also followed the Delhi High Court in the assessee's own case to hold that telecom data transmission payments to non-resident operators were not royalty, so the section 40(a)(i) disallowance for alleged non-deduction of tax was not sustainable under the treaty. The section 40(a)(ia) issue was sent back for verification because the amount had already been disallowed suo motu. On transfer pricing, the Tribunal accepted the limited risk model as consistently applied and sustained adjustment only to the extent of the shortfall in the agreed compensation.
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