Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Revised tax audit reports and corresponding revised returns filed before processing under section 143(1) require consideration despite filing after the prescribed due date where they correct disallowances based on Form 26A. Form 26A activates statutory relief from disallowance for non-deduction of tax at source, and the same expenditure cannot be disallowed again under section 40(a)(ia) after disallowance under section 43B(da). Rule 46A(3) does not require remand when materials were electronically furnished before processing and no fresh appellate evidence is admitted. After deletion of adjustments, set-off of brought-forward losses is academic where no positive income remains.
Revised tax audit reports and corresponding revised returns filed before processing under section 143(1) require consideration despite filing after the prescribed due date where they correct disallowances based on Form 26A. Form 26A activates statutory relief from disallowance for non-deduction of tax at source, and the same expenditure cannot be disallowed again under section 40(a)(ia) after disallowance under section 43B(da). Rule 46A(3) does not require remand when materials were electronically furnished before processing and no fresh appellate evidence is admitted. After deletion of adjustments, set-off of brought-forward losses is academic where no positive income remains.
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