Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Under the new tax regime, the Tribunal treated a previously filed Form 10IE as continuing where the assessee had already exercised the option and had not withdrawn it. It noted that the claim under section 115BAC for A.Y. 2023-24 could not be rejected merely because no fresh Form 10IE was filed for that year. The return should not have been processed under the old regime on that basis, and the Assessing Officer was directed to allow taxation under the new regime on the strength of the form already available on record.
Under the new tax regime, the Tribunal treated a previously filed Form 10IE as continuing where the assessee had already exercised the option and had not withdrawn it. It noted that the claim under section 115BAC for A.Y. 2023-24 could not be rejected merely because no fresh Form 10IE was filed for that year. The return should not have been processed under the old regime on that basis, and the Assessing Officer was directed to allow taxation under the new regime on the strength of the form already available on record.
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