Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Deduction u/s 80IA - The Revenue contended that the filing of Form 10CCB within the prescribed date is mandatory, while the assessee argued otherwise. The Tribunal, after analyzing the relevant legal provisions, concluded that while the filing of Form 10CCB is mandatory, adhering to the prescribed due date is not. The Tribunal also noted that the CIT(A) failed to properly consider legal precedents and independently assess the facts of the case. Consequently, the Tribunal set aside the CIT(A)'s decision and remanded the matter for fresh consideration.
Deduction u/s 80IA - The Revenue contended that the filing of Form 10CCB within the prescribed date is mandatory, while the assessee argued otherwise. The Tribunal, after analyzing the relevant legal provisions, concluded that while the filing of Form 10CCB is mandatory, adhering to the prescribed due date is not. The Tribunal also noted that the CIT(A) failed to properly consider legal precedents and independently assess the facts of the case. Consequently, the Tribunal set aside the CIT(A)'s decision and remanded the matter for fresh consideration.
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