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    <title>2017 (12) TMI 660 - ITAT MUMBAI</title>
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    <description>Revision under section 263 was unsustainable because the assessment was made after scrutiny and enquiry, and the Assessing Officer had adopted one permissible view on the tax treatment of the 3G spectrum cost; a mere difference of opinion could not justify revision. The right to use specified spectrum frequencies, acquired for business under an auction allotment, was treated as an intangible/commercial asset eligible for depreciation under section 32(1). Section 35ABB did not apply because the payment was not for acquisition of the telecom licence itself. The revision order was quashed and the depreciation claim was upheld.</description>
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    <pubDate>Wed, 06 Dec 2017 00:00:00 +0530</pubDate>
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      <title>2017 (12) TMI 660 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=352391</link>
      <description>Revision under section 263 was unsustainable because the assessment was made after scrutiny and enquiry, and the Assessing Officer had adopted one permissible view on the tax treatment of the 3G spectrum cost; a mere difference of opinion could not justify revision. The right to use specified spectrum frequencies, acquired for business under an auction allotment, was treated as an intangible/commercial asset eligible for depreciation under section 32(1). Section 35ABB did not apply because the payment was not for acquisition of the telecom licence itself. The revision order was quashed and the depreciation claim was upheld.</description>
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      <pubDate>Wed, 06 Dec 2017 00:00:00 +0530</pubDate>
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