Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Deduction u/s 80IA(4)(iv)(a) - deduction was inadvertently not claimed in the return of income filed - In our considered view, if the language of the Statute is plain and unambiguous and is not open to interpretation so that two views may be possible, then the same represents the legislative intent. Here, section 80A(5) of the Act states that for an assessee to be able to make a claim under Chapter -VI of the Act, such a claim has to be made in the return of income. - Fresh claim was rightly denied - AT
Deduction u/s 80IA(4)(iv)(a) - deduction was inadvertently not claimed in the return of income filed - In our considered view, if the language of the Statute is plain and unambiguous and is not open to interpretation so that two views may be possible, then the same represents the legislative intent. Here, section 80A(5) of the Act states that for an assessee to be able to make a claim under Chapter -VI of the Act, such a claim has to be made in the return of income. - Fresh claim was rightly denied - AT
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