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    <title>2010 (1) TMI 941 - ITAT, Ahmedabad</title>
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    <description>Telecommunication services were held to have commenced only in assessment year 1997-98, as actual commercial operations, not incorporation or licence grant, determined commencement. The amended section 80-IA regime was applied, allowing the assessee to claim deduction for any ten consecutive years out of fifteen, and earlier loss years did not bar the claim merely because no deduction had then been sought. Earlier losses and depreciation were required to be set off under section 80-IA(5), and licence fee paid on revenue-sharing basis was treated as revenue expenditure. Miscellaneous income and scrap sales were remanded for fresh adjudication, while interest under sections 234B and 234C and the revenue&#039;s challenges on sales promotion, passive infrastructure sharing receipts, and municipal tax provision were decided against the revenue.</description>
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    <pubDate>Fri, 29 Jan 2010 00:00:00 +0530</pubDate>
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      <title>2010 (1) TMI 941 - ITAT, Ahmedabad</title>
      <link>https://www.taxtmi.com/caselaws?id=209132</link>
      <description>Telecommunication services were held to have commenced only in assessment year 1997-98, as actual commercial operations, not incorporation or licence grant, determined commencement. The amended section 80-IA regime was applied, allowing the assessee to claim deduction for any ten consecutive years out of fifteen, and earlier loss years did not bar the claim merely because no deduction had then been sought. Earlier losses and depreciation were required to be set off under section 80-IA(5), and licence fee paid on revenue-sharing basis was treated as revenue expenditure. Miscellaneous income and scrap sales were remanded for fresh adjudication, while interest under sections 234B and 234C and the revenue&#039;s challenges on sales promotion, passive infrastructure sharing receipts, and municipal tax provision were decided against the revenue.</description>
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      <pubDate>Fri, 29 Jan 2010 00:00:00 +0530</pubDate>
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