https://www.taxtmi.com/caselaws?id=327053 Section 40(a)(ia) applies only where tax was deductible under the relevant TDS provision; because distributor discounts on prepaid vouchers and roaming or interconnect charges were not found subject to deduction under sections 194H or 194J, the disallowance could not survive. The Tribunal also held that the accounting treatment under AS-19 was not conclusive for lease rentals paid to IBM; the transaction had to be tested on its substance, and the agreement showed IBM retained effective ownership indicia during the term. On that footing, the lease rental was treated as revenue expenditure and the proposed capitalisation or amortisation under section 35ABB was rejected. en-us Thu, 21 Apr 2016 00:00:00 +0530 Sun, 01 May 2016 20:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327053 Section 40(a)(ia) applies only where tax was deductible under the relevant TDS provision; because distributor discounts on prepaid vouchers and roaming or interconnect charges were not found subject to deduction under sections 194H or 194J, the disallowance could not survive. The Tribunal also held that the accounting treatment under AS-19 was not conclusive for lease rentals paid to IBM; the transaction had to be tested on its substance, and the agreement showed IBM retained effective ownership indicia during the term. On that footing, the lease rental was treated as revenue expenditure and the proposed capitalisation or amortisation under section 35ABB was rejected. Case-Laws Income Tax Thu, 21 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327053