Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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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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