https://www.taxtmi.com/caselaws?id=794459 Transfer-pricing treatment of telecom-related payments requires comparable uncontrolled transactions for CUP benchmarking of brand royalty, while RBI-approved all-in-cost ceilings may provide a relevant benchmark for ECB interest and upfront fees. AMP expenditure cannot be treated as an international transaction merely because of high marketing spend; tangible evidence of an arrangement with an associated enterprise is required. Spectrum-use rights qualify as depreciable intangible assets. Telecom penalties that are compensatory and business-related may be deductible, whereas annual licence fees are capital and eligible only for amortisation under section 35ABB, subject to verification of the surviving licence period. Distributor discounts are not commission for tax withholding purposes. IBM hardware-use payments and WPC royalty charges may be revenue expenditure; liabilities written back remain taxable. en-us Tue, 30 Jun 2026 00:00:00 +0530 Mon, 06 Jul 2026 08:26:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794459 Transfer-pricing treatment of telecom-related payments requires comparable uncontrolled transactions for CUP benchmarking of brand royalty, while RBI-approved all-in-cost ceilings may provide a relevant benchmark for ECB interest and upfront fees. AMP expenditure cannot be treated as an international transaction merely because of high marketing spend; tangible evidence of an arrangement with an associated enterprise is required. Spectrum-use rights qualify as depreciable intangible assets. Telecom penalties that are compensatory and business-related may be deductible, whereas annual licence fees are capital and eligible only for amortisation under section 35ABB, subject to verification of the surviving licence period. Distributor discounts are not commission for tax withholding purposes. IBM hardware-use payments and WPC royalty charges may be revenue expenditure; liabilities written back remain taxable. Case-Laws Income Tax Tue, 30 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794459