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 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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