Brand promotion expenditure requires an established associated-enterprise arrangement for transfer pricing, while management cross-charges must accoun...
Reassessment after the ordinary limitation period requires the escaped-income threshold and independent sanction, without expanding jurisdiction throu...
Transfer pricing comparability requires turnover and functional analysis, alongside rules on exempt-income disallowance and amalgamation goodwill depr...
Form 10-IC's assessment-year mismatch, attributed to portal difficulties, does not by itself defeat a domestic company's concessional tax option where the option was exercised in a timely return and the form was filed within the relaxed deadline. The filing relaxation addressed genuine hardship for assessment year 2021-22. Concessional taxation remains subject to the other substantive conditions under section 115BAA. Section 115JB(5A)(ii) excludes minimum alternate tax where the section 115BAA option is exercised, with liability computed under the concessional regime and other applicable provisions and interest recomputed consequentially.
Form 10-IC's assessment-year mismatch, attributed to portal difficulties, does not by itself defeat a domestic company's concessional tax option where the option was exercised in a timely return and the form was filed within the relaxed deadline. The filing relaxation addressed genuine hardship for assessment year 2021-22. Concessional taxation remains subject to the other substantive conditions under section 115BAA. Section 115JB(5A)(ii) excludes minimum alternate tax where the section 115BAA option is exercised, with liability computed under the concessional regime and other applicable provisions and interest recomputed consequentially.
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