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    <title>2014 (3) TMI 496 - ITAT DELHI</title>
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    <description>Variable licence fee paid on a revenue-sharing basis after 1 August 1999 was treated as revenue expenditure and allowed in full, because only capital expenditure falls within section 35ABB. Interest on term loans and ESOP-related employee compensation were also deleted as disallowances. Lease charges and ABN Amro interest were remitted for fresh adjudication. Discount or free airtime to distributors attracted TDS under section 194H, so the corresponding disallowance under section 40(a)(ia) was sustained. Roaming charges were remanded for factual verification. Non-refundable security deposits were not taxed on receipt, and the transfer pricing adjustments for voice traffic and inter-corporate deposits were deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=245043</link>
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