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...
The Income Tax Appellate Tribunal (ITAT) held that the assessee is entitled to the concessional tax rate of 10% on royalty income u/s 115BBF, as the assessee had uploaded Form No. 3CFA before the completion of proceedings u/s 143(1) of the Income Tax Act. The ITAT set aside the order of the Additional/Joint Commissioner of Income Tax (Appeals), Panchkula, which had rejected the assessee's appeal and directed the Assessing Officer to tax the royalty income at the normal rate. The ITAT directed the Assessing Officer to tax the royalty income at the special rate of 10% against the normal rate adopted by the Centralized Processing Center (CPC). The grounds raised by the assessee were allowed.
The Income Tax Appellate Tribunal (ITAT) held that the assessee is entitled to the concessional tax rate of 10% on royalty income u/s 115BBF, as the assessee had uploaded Form No. 3CFA before the completion of proceedings u/s 143(1) of the Income Tax Act. The ITAT set aside the order of the Additional/Joint Commissioner of Income Tax (Appeals), Panchkula, which had rejected the assessee's appeal and directed the Assessing Officer to tax the royalty income at the normal rate. The ITAT directed the Assessing Officer to tax the royalty income at the special rate of 10% against the normal rate adopted by the Centralized Processing Center (CPC). The grounds raised by the assessee were allowed.
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