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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The High Court considered the issue of availing concessional tax rate u/s 115BAA and the requirement of electronically filing Form 10-IC. The assessee was taxed u/s 115JB for not filing Form 10-IC on time. The CIT (Appeal) upheld this decision, citing the mandatory requirement u/s 115BAA and Rule 21AE. The Tribunal found the assessee faced technical issues preventing the timely upload of Form 10-IC on the ITBA portal, despite filing it before the extended deadline. It was the first year the assessee sought such benefits. The Tribunal held that the technical error was not the fault of the assessee, allowing the benefit in the absence of any error in fact or law.
The High Court considered the issue of availing concessional tax rate u/s 115BAA and the requirement of electronically filing Form 10-IC. The assessee was taxed u/s 115JB for not filing Form 10-IC on time. The CIT (Appeal) upheld this decision, citing the mandatory requirement u/s 115BAA and Rule 21AE. The Tribunal found the assessee faced technical issues preventing the timely upload of Form 10-IC on the ITBA portal, despite filing it before the extended deadline. It was the first year the assessee sought such benefits. The Tribunal held that the technical error was not the fault of the assessee, allowing the benefit in the absence of any error in fact or law.
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