Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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