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...
Section 115BAA concessional corporate tax option requires cumulative compliance with prescribed conditions; claiming additional depreciation, which the regime prohibits, while calculating tax under the normal regime invalidates the option despite filing Form 10-IC. However, disallowance of additional depreciation through section 143(1) return processing is not permissible where it turns on a disputed legal position, particularly where the taxpayer's clarification was not considered. The invalid option therefore did not sustain the adjustment, which was deleted.
Section 115BAA concessional corporate tax option requires cumulative compliance with prescribed conditions; claiming additional depreciation, which the regime prohibits, while calculating tax under the normal regime invalidates the option despite filing Form 10-IC. However, disallowance of additional depreciation through section 143(1) return processing is not permissible where it turns on a disputed legal position, particularly where the taxpayer's clarification was not considered. The invalid option therefore did not sustain the adjustment, which was deleted.
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