Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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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