https://www.taxtmi.com/caselaws?id=458944 The ITAT Mumbai quashed the PCIT's revision order under section 263, ruling in favor of the assessee on two key issues. Regarding 3G spectrum fees depreciation, the tribunal held that the AO had properly examined and allowed depreciation under section 32(1)(ii) by treating spectrum rights as intangible assets, noting that section 35ABB was not applicable as section 35ABA was inserted only in 2016. The tribunal distinguished spectrum fees from license fees, emphasizing that spectrum rights alone don't entitle telecom service provision. On bad debts deduction under section 36(1)(vii), the tribunal found the AO had conducted proper enquiries before allowing the claim, and cited established precedents that written-off debts in books must be allowed as deductions. en-us Fri, 28 Aug 2020 00:00:00 +0530 Fri, 22 Nov 2024 19:15:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=458944 The ITAT Mumbai quashed the PCIT's revision order under section 263, ruling in favor of the assessee on two key issues. Regarding 3G spectrum fees depreciation, the tribunal held that the AO had properly examined and allowed depreciation under section 32(1)(ii) by treating spectrum rights as intangible assets, noting that section 35ABB was not applicable as section 35ABA was inserted only in 2016. The tribunal distinguished spectrum fees from license fees, emphasizing that spectrum rights alone don't entitle telecom service provision. On bad debts deduction under section 36(1)(vii), the tribunal found the AO had conducted proper enquiries before allowing the claim, and cited established precedents that written-off debts in books must be allowed as deductions. Case-Laws Income Tax Fri, 28 Aug 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=458944