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    <title>2026 (5) TMI 308 - ITAT DELHI</title>
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    <description>The Tribunal dealt with multiple income-tax adjustments involving distributor discounts, interconnectivity charges, spectrum amortisation, Government loan balances, ledger reconciliation differences, unreconciled DoT recoveries, TDS income verification, and section 14A disallowance. It held that earlier favourable precedents governed the distributor discount and overseas usage charge claims, so the section 40(a)(ia) disallowance failed. Spectrum charges for 3G and BWA were treated as allowable amortisation under section 35ABB, while duplicate taxation concerns led to deletion of the Government loan-related additions and the capital subsidy depreciation disallowance. Reconciliation-based additions were deleted, the TDS income issue was remanded for verification, and section 14A disallowance could not stand in the absence of exempt income.</description>
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      <title>2026 (5) TMI 308 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=791106</link>
      <description>The Tribunal dealt with multiple income-tax adjustments involving distributor discounts, interconnectivity charges, spectrum amortisation, Government loan balances, ledger reconciliation differences, unreconciled DoT recoveries, TDS income verification, and section 14A disallowance. It held that earlier favourable precedents governed the distributor discount and overseas usage charge claims, so the section 40(a)(ia) disallowance failed. Spectrum charges for 3G and BWA were treated as allowable amortisation under section 35ABB, while duplicate taxation concerns led to deletion of the Government loan-related additions and the capital subsidy depreciation disallowance. Reconciliation-based additions were deleted, the TDS income issue was remanded for verification, and section 14A disallowance could not stand in the absence of exempt income.</description>
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