https://www.taxtmi.com/caselaws?id=788901 The Tribunal held that later NLD/ILD telecom activity was only an of an existing eligible telecommunication undertaking, so deduction under section 80IA could not be proportionately denied; the disallowance was deleted. It also held that payments to foreign operators for data transmission and telecom connectivity were not royalty under the applicable treaty, and retrospective domestic amendments could not enlarge the treaty definition, so no withholding failure arose and the section 40(a)(i) disallowance was deleted. An ad hoc disallowance on office running and maintenance expenses was remanded for factual verification. The transfer pricing adjustment was not sustained in full because the assessee's operating model, agreed remuneration mechanism, and prior-year acceptance could not be ignored without contrary material; only partial adjustment remained. en-us Wed, 25 Feb 2026 00:00:00 +0530 Fri, 27 Mar 2026 16:47:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788901 The Tribunal held that later NLD/ILD telecom activity was only an of an existing eligible telecommunication undertaking, so deduction under section 80IA could not be proportionately denied; the disallowance was deleted. It also held that payments to foreign operators for data transmission and telecom connectivity were not royalty under the applicable treaty, and retrospective domestic amendments could not enlarge the treaty definition, so no withholding failure arose and the section 40(a)(i) disallowance was deleted. An ad hoc disallowance on office running and maintenance expenses was remanded for factual verification. The transfer pricing adjustment was not sustained in full because the assessee's operating model, agreed remuneration mechanism, and prior-year acceptance could not be ignored without contrary material; only partial adjustment remained. Case-Laws Income Tax Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788901