Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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.
Note: It is a system-generated summary and is for quick reference only.