Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Denial of benefit u/s 115BAA of reduced rate of tax @22% - Domestic Companies - Condonation of delay in filing of Form No. 10-IC by the assessee - The Appellate Tribunal carefully evaluates the submissions and the provisions of Circular No. 19/2023. It observes that the assessee has indeed fulfilled all the conditions mentioned in the circular for condoning the delay in filing Form No. 10-IC. Firstly, the assessee filed its income tax return within the due date specified under Section 139(1) of the Income Tax Act. Secondly, the option for taxation under Section 115BAA was duly exercised by the assessee in the filed return. Lastly, Form No. 10-IC was electronically filed within the extended timeline provided by the circular. - Given that the assessee has met all the prescribed conditions, the Appellate Tribunal concludes that the delay in filing Form No. 10-IC should be condoned.
Denial of benefit u/s 115BAA of reduced rate of tax @22% - Domestic Companies - Condonation of delay in filing of Form No. 10-IC by the assessee - The Appellate Tribunal carefully evaluates the submissions and the provisions of Circular No. 19/2023. It observes that the assessee has indeed fulfilled all the conditions mentioned in the circular for condoning the delay in filing Form No. 10-IC. Firstly, the assessee filed its income tax return within the due date specified under Section 139(1) of the Income Tax Act. Secondly, the option for taxation under Section 115BAA was duly exercised by the assessee in the filed return. Lastly, Form No. 10-IC was electronically filed within the extended timeline provided by the circular. - Given that the assessee has met all the prescribed conditions, the Appellate Tribunal concludes that the delay in filing Form No. 10-IC should be condoned.
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