Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
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Deduction u/s. 80IB(10) - non filling of return on time - the ITAT held that the return filed beyond the due date cannot claim deduction under section 80IB(10) as per the Supreme Court's decision in Wipro Ltd. vs. Pr. CIT. - The ITAT further observed that, the reasoning given by the assessee that within a period of six months from the date of filing of return of income for assessment year 2006- 07, the assessee have filed return of income for assessment year 2007-08 will not help the assessee as the assessee was very well aware of mandatory date of filing the original return of income.
Deduction u/s. 80IB(10) - non filling of return on time - the ITAT held that the return filed beyond the due date cannot claim deduction under section 80IB(10) as per the Supreme Court's decision in Wipro Ltd. vs. Pr. CIT. - The ITAT further observed that, the reasoning given by the assessee that within a period of six months from the date of filing of return of income for assessment year 2006- 07, the assessee have filed return of income for assessment year 2007-08 will not help the assessee as the assessee was very well aware of mandatory date of filing the original return of income.
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