Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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