https://www.taxtmi.com/caselaws?id=794459 The article reviews ITAT Mumbai's treatment of transfer pricing and deduction issues in an assessee's telecom case. It notes that brand royalty, ECB interest and upfront fee, and AMP adjustments were deleted because CUP benchmarking required uncontrolled comparables, RBI-approved borrowing ceilings were relevant, and AMP spending could not be presumed to be an international transaction without tangible evidence. It also states that depreciation was allowed on the right to use 3G spectrum, penalty paid to DOT and IBM/WPC-related payments were treated as revenue outgoings, and prepaid distributor discount was not hit by section 40(a)(ia). Liabilities written back were held taxable, while asset restoration cost and licence fee amortisation required limited verification and recomputation. 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 The article reviews ITAT Mumbai's treatment of transfer pricing and deduction issues in an assessee's telecom case. It notes that brand royalty, ECB interest and upfront fee, and AMP adjustments were deleted because CUP benchmarking required uncontrolled comparables, RBI-approved borrowing ceilings were relevant, and AMP spending could not be presumed to be an international transaction without tangible evidence. It also states that depreciation was allowed on the right to use 3G spectrum, penalty paid to DOT and IBM/WPC-related payments were treated as revenue outgoings, and prepaid distributor discount was not hit by section 40(a)(ia). Liabilities written back were held taxable, while asset restoration cost and licence fee amortisation required limited verification and recomputation. Case-Laws Income Tax Tue, 30 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794459