Telecom Tax Victory: ITAT Deletes Rs. 120 Cr Royalty TP Adjustment, Allows 3G Spectrum Depreciation

Vodafone Idea Ltd Vs ACIT (ITAT Delhi) Vodafone Idea  challenged the final assessment framed u/s 143(3) r.w.s. 144C for AY 2012-13 involving several major disallowances & TP adjustments; Delhi ITAT grants sweeping relief to Vodafone Idea – Royalty, Spectrum, Roaming & DoT penalty allowed Tribunal deleted the TP adjustment of ₹120.54 crore on royalty for ‘Vodafone’ & ‘Essar’ brands, holding that TPO wrongly used controlled comparables (Virgin Group), relying on earlier Vodafone group rulings. Depreciation of ₹12,471.74 crore on 3G spectrum was allowed as intangible a...