Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Form 10-IC filed within the applicable due date preserved the option for the concessional corporate tax regime, because the due date under section 139(1) depends on the assessee's class and is not advanced merely by belated filing of Form 3CEB or an incorrect return selection. The text notes that later furnishing of the transfer-pricing report before assessment did not justify denial of the option. Once the option under section 115BAA was validly exercised, tax had to be computed under that regime and MAT under section 115JB could not be applied.
Form 10-IC filed within the applicable due date preserved the option for the concessional corporate tax regime, because the due date under section 139(1) depends on the assessee's class and is not advanced merely by belated filing of Form 3CEB or an incorrect return selection. The text notes that later furnishing of the transfer-pricing report before assessment did not justify denial of the option. Once the option under section 115BAA was validly exercised, tax had to be computed under that regime and MAT under section 115JB could not be applied.
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