Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Levy of penalty u/s 234E - delay of 484 days in filling Form No. 26Q (TDS Return) - technical glitches on the part of the system - The ITAT allowed the appeals, focusing on the legal and technical nuances presented. The tribunal found that the appeals were filed within the extended limitation period provided by the Supreme Court due to the COVID-19 pandemic. It also highlighted that the technical issues faced by the assessee in filing TDS returns were not considered by the CIT(A), which led to an unjust imposition of late fees.
Levy of penalty u/s 234E - delay of 484 days in filling Form No. 26Q (TDS Return) - technical glitches on the part of the system - The ITAT allowed the appeals, focusing on the legal and technical nuances presented. The tribunal found that the appeals were filed within the extended limitation period provided by the Supreme Court due to the COVID-19 pandemic. It also highlighted that the technical issues faced by the assessee in filing TDS returns were not considered by the CIT(A), which led to an unjust imposition of late fees.
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