Passive infrastructure demerger transfer treated as gift; depreciation, TDS, 14A, 194H disallowances deleted; rentals remanded, 80IA allowed

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....Transfer of passive infrastructure assets pursuant to a court-approved demerger was held to constitute a "gift" covered by section 47(iii) and therefore not a "transfer" under section 2(47), negating the Revenue's case for depreciation-related disallowance; the Revenue's ground was dismissed. Network site rentals disallowed as excessive under section 40A(2)(b) were restored for de novo examination due to lack of factual inquiry into cost/value basis; remand ordered. Disallowance under section 14A was deleted as no exempt income was earned. Roaming charge disallowance under sections 40(a)(ia)/40(a)(i) for alleged TDS default was deleted, following binding precedent. Trade discounts on prepaid distribution were held outside section 194H; disa.........