Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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.