Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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A one-day delay in uploading Form 10DA for the additional employment deduction was treated as a procedural lapse, not a substantive defect, because the form was already on record before the section 143(1) intimation. The Tribunal followed co-ordinate Bench rulings that the prescribed form is a compliance requirement for verification, and the claim cannot be denied once the form is available before assessment or intimation. Reliance on Wipro was distinguished as an exemption-case authority, not a deduction-case authority. The disallowance was deleted and the deduction allowed.
A one-day delay in uploading Form 10DA for the additional employment deduction was treated as a procedural lapse, not a substantive defect, because the form was already on record before the section 143(1) intimation. The Tribunal followed co-ordinate Bench rulings that the prescribed form is a compliance requirement for verification, and the claim cannot be denied once the form is available before assessment or intimation. Reliance on Wipro was distinguished as an exemption-case authority, not a deduction-case authority. The disallowance was deleted and the deduction allowed.
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