allowable as a
revenue expenditure and it should be amortised under section 35ABB
of the Act.
4.2 On the facts and circumstances of the case ... capital expenditure amortizable
under section 35ABB of the Act.
5. Ground No. 5 - Disallowance of unexplained investment
5.1 On the facts and circumstances
license fee term commencing from
A.Y. 2004-05 as per section 35ABB of I.T. Act, as allowed by the
AO vide assessment order ... above amount for deduction in full as
revenue expenditure u/s 35ABB of the Act basing on the cutoff
date of 01.04.2005 for migration
further
directing the AO to instead allow deduction under section 35ABB of the Act
on the ground that the 3G Spectrum was only an extension ... further
directing the AO to instead allow deduction under
section 35ABB of the Act on the same on the
ground that the 3G spectrum
fees
paid by assessee in Phase -I-as deductible expenditure u/s
35ABB(1) during the year under consideration ... being 1/10th of the total
license fees claimed u/s 35ABB of the Act. In view of our
fining in ground
case of other group companies
and amortization has been done u/s 35ABB of the Act, the AO
concluded that since the license was granted ... amount of amortization of
license fee and spectrum charges u/s 35ABB of the Act.
3
ITA No.3619/Del/2014
scientific
research, section 35AB deals with expenditure on know-how and
section 35ABB deals with expenditure for obtaining licence to operate
telecommunication services. Section 35AC
Support Service Expenditure 13,42,85,216/-
Less : Deduction allowed for
35ABB 1,44,41,953/-
Total Additions
addition of Rs.
57,40,488/- made by AO u/s 35ABB for expenses
incurred towards liquidated damages and interest
thereon paid to Department ... account of expenses incurred
towards liquidated damages u/s 35ABB of the Income Tax Act, 1961
(hereinafter referred to as the Act).
4. As regard
which is deductible
Page 2 of 3
expenditure under section 35ABB of the income tax act. The revenue Aggrieved by
the order ... High Court in case
of the assessee wherein the issue of section 35ABB has been decided holding that
the amount equal
