Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Processing of invalid return u/s 143(1) - Denial of exemption u/s 10(23C)(iiiad) - non-filing of ITR-V within 120 days made the assessee’s return as ‘invalid’ being deemed to have been never filed which was picked for processing - Assessee filed 2nd belated return u/s 139(4) - The ITAT held that, since the initial return was invalid, the intimation issued by the CPC based on it was also invalid. The CPC should have considered the second valid return available in the departmental database at the time of processing under section 143(1).
Processing of invalid return u/s 143(1) - Denial of exemption u/s 10(23C)(iiiad) - non-filing of ITR-V within 120 days made the assessee’s return as ‘invalid’ being deemed to have been never filed which was picked for processing - Assessee filed 2nd belated return u/s 139(4) - The ITAT held that, since the initial return was invalid, the intimation issued by the CPC based on it was also invalid. The CPC should have considered the second valid return available in the departmental database at the time of processing under section 143(1).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
