Prior APA methodology guides transfer pricing benchmarking where consistent FAR profiles support comparability and arm's length margins eliminate adju...
Battery-integrated tablet rear covers classify as lithium-ion accumulators when protective components enable the battery's active energy-storage funct...
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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