Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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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