Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Deduction u/s. 80JJAA - claim made was disallowed to the assessee because it was not included in the return of income filed by the assessee - Assessee did not have the opportunity to raise the contention before the AO as its return was processed by CPC, Bangalore and intimation was issued u/s. 143(1) and, therefore, the assessee had no opportunity to make a fresh claim by way of filing a revised return before the CPC, Bangalore since the process is completed. The claim made by the assessee at the first appellate stage is an allowable claim. - AT
Deduction u/s. 80JJAA - claim made was disallowed to the assessee because it was not included in the return of income filed by the assessee - Assessee did not have the opportunity to raise the contention before the AO as its return was processed by CPC, Bangalore and intimation was issued u/s. 143(1) and, therefore, the assessee had no opportunity to make a fresh claim by way of filing a revised return before the CPC, Bangalore since the process is completed. The claim made by the assessee at the first appellate stage is an allowable claim. - AT
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