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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
New scheme for Tax on income of individuals and Hindu undivided family u/s 115BAC - Assessee had not filed Form 10-IE for opting the new tax regime within the stipulated time - The Appellate Tribunal referred to Section 115BAC of the Income Tax Act, which states that if an individual fails to satisfy certain conditions for opting the new tax regime, the option becomes invalid for the relevant assessment year, and the income is computed as per the old scheme. Since the assessee filed the return after the due date, the Tribunal upheld the AO's decision to assess the income under the old scheme. - Regarding denial of Deductions: the Tribunal allowed the appeal for statistical purposes, directing the assessing officer to re-examine the issue based on evidence and submissions provided by the assessee, ensuring a fair opportunity for the assessee to present their case.
New scheme for Tax on income of individuals and Hindu undivided family u/s 115BAC - Assessee had not filed Form 10-IE for opting the new tax regime within the stipulated time - The Appellate Tribunal referred to Section 115BAC of the Income Tax Act, which states that if an individual fails to satisfy certain conditions for opting the new tax regime, the option becomes invalid for the relevant assessment year, and the income is computed as per the old scheme. Since the assessee filed the return after the due date, the Tribunal upheld the AO's decision to assess the income under the old scheme. - Regarding denial of Deductions: the Tribunal allowed the appeal for statistical purposes, directing the assessing officer to re-examine the issue based on evidence and submissions provided by the assessee, ensuring a fair opportunity for the assessee to present their case.
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