Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
