Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Sub-section (5) of section 115BAA provides that the lower tax rate option once exercised shall apply to subsequent years. The 2nd proviso states that once opted, it cannot be withdrawn for the same or any other previous year. The assessee validly opted for 115BAA for AY 2020-21 by filing Form 10IC, and the revenue authorities allowed the lower rate. Since the assessee did not violate any condition for AY 2020-21, and the valid option was exercised, the assessee is eligible for the lower rate for subsequent assessment years too, subject to other conditions under the Act. The assessee's appeal is allowed.
Sub-section (5) of section 115BAA provides that the lower tax rate option once exercised shall apply to subsequent years. The 2nd proviso states that once opted, it cannot be withdrawn for the same or any other previous year. The assessee validly opted for 115BAA for AY 2020-21 by filing Form 10IC, and the revenue authorities allowed the lower rate. Since the assessee did not violate any condition for AY 2020-21, and the valid option was exercised, the assessee is eligible for the lower rate for subsequent assessment years too, subject to other conditions under the Act. The assessee's appeal is allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
