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...
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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