https://www.taxtmi.com/caselaws?id=472537 Comparable Uncontrolled Price benchmarking requires an uncontrolled royalty transaction; associated-enterprise agreements cannot serve as comparables. Advertisement, marketing and promotion spend does not alone establish an international transaction, and the Bright Line Test cannot presume brand-building services. Annual telecom licence fees are capital and amortised over the unexpired licence period, whereas 3G spectrum rights are depreciable intangible assets. Automated roaming and prepaid-distributor discounts do not trigger withholding as technical-service fees or commission. Recurring telecom royalties, contractual licence-breach payments, business-promotion costs and subscriber-fraud losses are deductible where applicable. Cell-site sharing and ordinary miscellaneous receipts may qualify as eligible telecom-business income, unlike export incentives; crystallisation and certain income exclusions require verification. en-us Mon, 11 May 2026 00:00:00 +0530 Wed, 14 Oct 2026 18:57:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472537 Comparable Uncontrolled Price benchmarking requires an uncontrolled royalty transaction; associated-enterprise agreements cannot serve as comparables. Advertisement, marketing and promotion spend does not alone establish an international transaction, and the Bright Line Test cannot presume brand-building services. Annual telecom licence fees are capital and amortised over the unexpired licence period, whereas 3G spectrum rights are depreciable intangible assets. Automated roaming and prepaid-distributor discounts do not trigger withholding as technical-service fees or commission. Recurring telecom royalties, contractual licence-breach payments, business-promotion costs and subscriber-fraud losses are deductible where applicable. Cell-site sharing and ordinary miscellaneous receipts may qualify as eligible telecom-business income, unlike export incentives; crystallisation and certain income exclusions require verification. Case-Laws Income Tax Mon, 11 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472537