Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
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...
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).
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