The ITAT Mumbai upheld the deduction of approximately Rs. 1.10 lakh crore in operational costs despite their book capitalisation as CWIP, affirming that the substantive nature of expenditure prevails over accounting labels for tax purposes. The Tribunal further ruled that overseas voice termination and bandwidth payments do not constitute royalty or technical fees, thereby precluding withholding obligations and Section 40(a)(i) disallowances.
Reliance Jio Wins Rs 1.1 Lakh Crore Tax Dispute
