https://www.taxtmi.com/caselaws?id=464405 ITAT MUMBAI (AT) held that discounts to distributors for prepaid SIMs are not commission liable to TDS under s.194H and disallowance u/s.40(a)(ia) is not warranted. Domestic roaming payments to other operators do not constitute FTS attracting s.194J, so no TDS disallowance. Amortisation of ESOP intrinsic value charged to P&L is allowable under s.37(1) and not to be disallowed; related ESOP compensation need not be added back for book profit under s.115JB. Interest on acquisition of shares was allowed following applicable SC/HC precedents. No disallowance u/s.14A arises where no exempt income exists. Revenue-share license fees deductible as revenue expenditure under s.37(1). en-us Thu, 27 Jul 2023 00:00:00 +0530 Tue, 28 Oct 2025 10:43:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464405 ITAT MUMBAI (AT) held that discounts to distributors for prepaid SIMs are not commission liable to TDS under s.194H and disallowance u/s.40(a)(ia) is not warranted. Domestic roaming payments to other operators do not constitute FTS attracting s.194J, so no TDS disallowance. Amortisation of ESOP intrinsic value charged to P&L is allowable under s.37(1) and not to be disallowed; related ESOP compensation need not be added back for book profit under s.115JB. Interest on acquisition of shares was allowed following applicable SC/HC precedents. No disallowance u/s.14A arises where no exempt income exists. Revenue-share license fees deductible as revenue expenditure under s.37(1). Case-Laws Income Tax Thu, 27 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464405