Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Belated filing of Form 10E did not, by itself, defeat the assessee's claim for tax relief where entitlement was otherwise admissible in law. The Tribunal applied a liberal construction to the filing requirement, treating the delay as a procedural lapse that should not override substantive rights. It held that the claim had to be examined and verified by the AO/CPC once the form was on record. The impugned order was set aside and the matter remanded for verification of Form 10E and grant of relief if found admissible.
Belated filing of Form 10E did not, by itself, defeat the assessee's claim for tax relief where entitlement was otherwise admissible in law. The Tribunal applied a liberal construction to the filing requirement, treating the delay as a procedural lapse that should not override substantive rights. It held that the claim had to be examined and verified by the AO/CPC once the form was on record. The impugned order was set aside and the matter remanded for verification of Form 10E and grant of relief if found admissible.
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