Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The Income Tax Appellate Tribunal held that the denial of exemption u/s 10(23C)(iiiab) for late filing of the income tax return beyond the time specified u/s 139(1) or for filing the return u/s 139(4D) instead of Section 139(4C) is not justified. The Tribunal ruled that the Department could not point out any relevant provision that disentitles the assessee from claiming exemption u/s 10(23C)(iiiab) for non-filing or late filing of the return. Consequently, the action of the lower authorities in denying the exemption on these grounds was set aside, and the Assessing Officer was directed to grant the exemption claimed u/s 10(23C)(iiiab). The assessee's appeal was allowed.
The Income Tax Appellate Tribunal held that the denial of exemption u/s 10(23C)(iiiab) for late filing of the income tax return beyond the time specified u/s 139(1) or for filing the return u/s 139(4D) instead of Section 139(4C) is not justified. The Tribunal ruled that the Department could not point out any relevant provision that disentitles the assessee from claiming exemption u/s 10(23C)(iiiab) for non-filing or late filing of the return. Consequently, the action of the lower authorities in denying the exemption on these grounds was set aside, and the Assessing Officer was directed to grant the exemption claimed u/s 10(23C)(iiiab). The assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
