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    <title>2026 (6) TMI 1253 - ITAT MUMBAI</title>
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    <description>Depreciation on passive infrastructure assets transferred under a court-sanctioned demerger was held allowable, while network site rentals to Indus Towers required fresh factual examination and were remanded. Section 14A disallowance was held inapplicable where no exempt income arose, and the corresponding MAT adjustment under section 115JB was deleted. Roaming charges were treated as non-technical automated telecom services, so TDS-based disallowance failed. Depreciation on 3G spectrum fees was allowed as an intangible asset, while section 80IA deduction was allowed on ancillary telecom receipts including scrap sales, site sharing, IRU revenue and related income. The transfer pricing adjustment on ECB interest and upfront fee was deleted, telecom licence fee was held subject to amortisation under section 35ABB, and royalty-related objections were rejected.</description>
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    <pubDate>Thu, 02 Apr 2026 00:00:00 +0530</pubDate>
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      <description>Depreciation on passive infrastructure assets transferred under a court-sanctioned demerger was held allowable, while network site rentals to Indus Towers required fresh factual examination and were remanded. Section 14A disallowance was held inapplicable where no exempt income arose, and the corresponding MAT adjustment under section 115JB was deleted. Roaming charges were treated as non-technical automated telecom services, so TDS-based disallowance failed. Depreciation on 3G spectrum fees was allowed as an intangible asset, while section 80IA deduction was allowed on ancillary telecom receipts including scrap sales, site sharing, IRU revenue and related income. The transfer pricing adjustment on ECB interest and upfront fee was deleted, telecom licence fee was held subject to amortisation under section 35ABB, and royalty-related objections were rejected.</description>
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