Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The ITAT Ahmedabad ruled in favor of the assessee regarding the addition u/s 80JJAA claim denial. The chartered accountant filed Form 10DA before the return filing deadline, which was not disputed by the Department. Although the report was not accepted by the assessee before the due date, it was later accepted before the assessment order was passed. Citing a Gujarat High Court case, the Tribunal held that the filing of the report is procedural, and if available to the assessing officer before assessment, the deduction claim cannot be denied. The appeal of the assessee was allowed.
The ITAT Ahmedabad ruled in favor of the assessee regarding the addition u/s 80JJAA claim denial. The chartered accountant filed Form 10DA before the return filing deadline, which was not disputed by the Department. Although the report was not accepted by the assessee before the due date, it was later accepted before the assessment order was passed. Citing a Gujarat High Court case, the Tribunal held that the filing of the report is procedural, and if available to the assessing officer before assessment, the deduction claim cannot be denied. The appeal of the assessee was allowed.
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