Transfer Pricing Officer jurisdiction is transaction-specific, excluding permanent establishment determinations and requiring independent assessment o...
Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
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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