Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
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Deduction under 80JJAA could not be denied on limitation where the return of income and Form No. 10DA were filed on 30.11.2018, the due date recorded in the statutory intimation. The Tribunal found that the appellate authority had wrongly assumed the due date under section 139(1) was 31.10.2018, and that assumption led to an erroneous disallowance. As the filing was within the recorded due date, the statutory condition for rejection was not breached. The deduction was held allowable and the Assessing Officer was directed to allow the claim.
Deduction under 80JJAA could not be denied on limitation where the return of income and Form No. 10DA were filed on 30.11.2018, the due date recorded in the statutory intimation. The Tribunal found that the appellate authority had wrongly assumed the due date under section 139(1) was 31.10.2018, and that assumption led to an erroneous disallowance. As the filing was within the recorded due date, the statutory condition for rejection was not breached. The deduction was held allowable and the Assessing Officer was directed to allow the claim.
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