Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Deduction u/s 80IA was allowed despite delay in filing Form 10CCB due to technical glitches on the Income Tax portal. The form was filed 1 hour 22 minutes after the due date of 31.10.2022. CIT(A) relied on the assessee's statement and allowed the deduction. ITAT held that the delay was beyond the assessee's control and cannot be construed as discrepancy or failure on their part. The prescribed form was available before AO when return was processed. Case laws on exemption notifications and CBDT Circular 9/2015 regarding delay in filing refund claim and carry forward losses were deemed irrelevant. As the form was filed before the due date of return filing with a slight delay, and the delay was not due to negligence or inaction by the assessee, the deduction was allowed in the interest of justice. The delay was not attributed to the assessee, hence no penal action was imposed.
Deduction u/s 80IA was allowed despite delay in filing Form 10CCB due to technical glitches on the Income Tax portal. The form was filed 1 hour 22 minutes after the due date of 31.10.2022. CIT(A) relied on the assessee's statement and allowed the deduction. ITAT held that the delay was beyond the assessee's control and cannot be construed as discrepancy or failure on their part. The prescribed form was available before AO when return was processed. Case laws on exemption notifications and CBDT Circular 9/2015 regarding delay in filing refund claim and carry forward losses were deemed irrelevant. As the form was filed before the due date of return filing with a slight delay, and the delay was not due to negligence or inaction by the assessee, the deduction was allowed in the interest of justice. The delay was not attributed to the assessee, hence no penal action was imposed.
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