https://www.taxtmi.com/caselaws?id=766320 ITAT Mumbai allowed partial relief to the appellant in multiple tax disputes. The tribunal deleted disallowance under Section 14A read with Rule 8D(2)(ii) and directed recomputation under Rule 8D(2)(iii) considering only exempt income investments. For MAT computation under Section 115JB, AO was directed to recompute on reasonable basis. TDS disallowance under Section 40(a)(ia) for pre-paid distributor discounts was deleted, following precedent that upfront discounts don't attract Section 194H. Depreciation on 3G spectrum was allowed under Section 32(1)(ii) instead of amortization under Section 35ABB. IBM service payment issue was remanded for verification of agreements and supporting documents. Transfer pricing adjustments for brand royalty and expense reimbursements were remanded to TPO/AO for fresh consideration with proper benchmarking and documentation. en-us Tue, 18 Feb 2025 00:00:00 +0530 Sat, 22 Feb 2025 08:30:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766320 ITAT Mumbai allowed partial relief to the appellant in multiple tax disputes. The tribunal deleted disallowance under Section 14A read with Rule 8D(2)(ii) and directed recomputation under Rule 8D(2)(iii) considering only exempt income investments. For MAT computation under Section 115JB, AO was directed to recompute on reasonable basis. TDS disallowance under Section 40(a)(ia) for pre-paid distributor discounts was deleted, following precedent that upfront discounts don't attract Section 194H. Depreciation on 3G spectrum was allowed under Section 32(1)(ii) instead of amortization under Section 35ABB. IBM service payment issue was remanded for verification of agreements and supporting documents. Transfer pricing adjustments for brand royalty and expense reimbursements were remanded to TPO/AO for fresh consideration with proper benchmarking and documentation. Case-Laws Income Tax Tue, 18 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766320