<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2018 (6) TMI 1029 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=362202</link>
    <description>Ad hoc disallowance of commission and spectrum royalty was deleted because the expenditure was evidenced and the recurring spectrum-related payment was revenue in nature, not expenditure for obtaining a licence under section 35ABB. Recurring licence fee payable after the telecom policy change was also treated as a revenue outgoing, so amortisation under section 35ABB was denied. Depreciation on notional restoration cost was rejected for want of actual cost, while interest on capital work-in-progress was remitted for fresh verification. Roaming charges were held outside section 40(a)(ia), distributor discount was disallowable only partly, and penalty paid to the Department of Telecommunications was held compensatory, not barred by Explanation 1 to section 37(1). Section 80IA relief was allowed substantially, the section 68 addition was remanded, and transfer pricing adjustments for brand royalty and AMP were set aside for reconsideration.</description>
    <language>en-us</language>
    <pubDate>Wed, 14 Mar 2018 00:00:00 +0530</pubDate>
    <lastBuildDate>Thu, 06 Sep 2018 09:58:00 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=524316" rel="self" type="application/rss+xml"/>
    <item>
      <title>2018 (6) TMI 1029 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=362202</link>
      <description>Ad hoc disallowance of commission and spectrum royalty was deleted because the expenditure was evidenced and the recurring spectrum-related payment was revenue in nature, not expenditure for obtaining a licence under section 35ABB. Recurring licence fee payable after the telecom policy change was also treated as a revenue outgoing, so amortisation under section 35ABB was denied. Depreciation on notional restoration cost was rejected for want of actual cost, while interest on capital work-in-progress was remitted for fresh verification. Roaming charges were held outside section 40(a)(ia), distributor discount was disallowable only partly, and penalty paid to the Department of Telecommunications was held compensatory, not barred by Explanation 1 to section 37(1). Section 80IA relief was allowed substantially, the section 68 addition was remanded, and transfer pricing adjustments for brand royalty and AMP were set aside for reconsideration.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Wed, 14 Mar 2018 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=362202</guid>
    </item>
  </channel>
</rss>