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of <h1>Section 52 requires time-spread amortisation for amalgamation/demerger costs, voluntary retirement payments, spectrum and licence fees with transfer rules</h1> Section 52 mandates time-spread amortisation for four expenditure types-amalgamation/demerger costs, voluntary retirement payments, spectrum fees and licence fees-specifying initial years and equal instalments or co-terminous periods for telecom rights, disallowing depreciation or other deductions where applicable, prescribing treatment on partial/full transfers (proceeds offset unallowed expenditure; excess taxed), and preserving continuity on transfers within amalgamation/demerger. The Act and original Bill are largely aligned; drafting differences are minor, but the Act's reorganisation continuity clause adds 'as far as may be' and ties successor entitlements to how the predecessor would have been treated, affording interpretive flexibility and broader rule-making phrasing.
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