Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Filing of Form 10-IE to opt for the new tax regime u/s 115BAC is directory, not mandatory. If filed before assessment, the Assessing Officer must consider it. The requirement to file Form 67 for Foreign Tax Credit before the due date u/s 139(1) is also directory. Technical glitches preventing timely filing should not deprive the assessee of benefits, as held by the High Court. The Tribunal directed the CPC to consider Form 10-IE filed by the assessee and pass appropriate orders, allowing the appeal for statistical purposes.
Filing of Form 10-IE to opt for the new tax regime u/s 115BAC is directory, not mandatory. If filed before assessment, the Assessing Officer must consider it. The requirement to file Form 67 for Foreign Tax Credit before the due date u/s 139(1) is also directory. Technical glitches preventing timely filing should not deprive the assessee of benefits, as held by the High Court. The Tribunal directed the CPC to consider Form 10-IE filed by the assessee and pass appropriate orders, allowing the appeal for statistical purposes.
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