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 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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