Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
The Tribunal addressed multiple tax adjustments in telecom operations, deleting disallowances under section 40(a)(ia) for distributor discounts and under section 40(a)(i) for interconnect usage charges by following binding precedent in the assessee's own earlier years. It allowed amortisation of one-time 3G and BWA spectrum payments under section 35ABB on the basis that the right to operate telecom services had been acquired and the spectrum was put to use, and it deleted related enhancement and depreciation disallowance as a double adjustment. It also held that principal loan repayments were outside section 43B, removed additions based on inventory and internal reconciliation differences, upheld deletion of the DoT current account addition, and deleted section 14A disallowance because no exempt income was received. One TDS-related issue was remitted for verification.
The Tribunal addressed multiple tax adjustments in telecom operations, deleting disallowances under section 40(a)(ia) for distributor discounts and under section 40(a)(i) for interconnect usage charges by following binding precedent in the assessee's own earlier years. It allowed amortisation of one-time 3G and BWA spectrum payments under section 35ABB on the basis that the right to operate telecom services had been acquired and the spectrum was put to use, and it deleted related enhancement and depreciation disallowance as a double adjustment. It also held that principal loan repayments were outside section 43B, removed additions based on inventory and internal reconciliation differences, upheld deletion of the DoT current account addition, and deleted section 14A disallowance because no exempt income was received. One TDS-related issue was remitted for verification.
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