Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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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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