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...
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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 The 2nd proviso states that once opted, it cannot be withdrawn for the same or any other previous year.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 The 2nd proviso states that once opted, it cannot be withdrawn for the same or any other previous year.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.
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