SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
The Appellate Tribunal considered the disallowance of deduction claimed u/s 80-IA due to the assessee's failure to file Form no.10CCB on time. The Tribunal found that the audit report was filed online by the assessee, albeit with a delay. The Tribunal disagreed with the lower authorities' decision, citing that the Supreme Court's ruling in Wipro Ltd. did not support the Revenue's case. The Tribunal noted that the amendment to section 80-IA(7) by the Finance Act, 2020, was not applicable to the assessment year in question. As the audit report was filed within the allowed time, the disallowance of the deduction u/s 80-IA was overturned, and the assessee's appeal was allowed.
The Appellate Tribunal considered the disallowance of deduction claimed u/s 80-IA due to the assessee's failure to file Form no.10CCB on time. The Tribunal found that the audit report was filed online by the assessee, albeit with a delay. The Tribunal disagreed with the lower authorities' decision, citing that the Supreme Court's ruling in Wipro Ltd. did not support the Revenue's case. The Tribunal noted that the amendment to section 80-IA(7) by the Finance Act, 2020, was not applicable to the assessment year in question. As the audit report was filed within the allowed time, the disallowance of the deduction u/s 80-IA was overturned, and the assessee's appeal was allowed.
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TaxTMI 
TaxTMI 
of 4894 
