Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
The HC directed the respondents to modify the tax filing system for AY 2024-25 to allow assessees to claim the rebate u/s 87A of the Income Tax Act, 1961. The statutory right to claim rebate cannot be overridden by procedural changes like software utility. The rebate is linked to total income and tax liability, with the onus on tax authorities to ensure proper implementation if statutory criteria are met. Procedural impediments depriving statutory benefits warrant judicial intervention. As interim relief, the CBDT was directed to extend the due date for e-filing returns till 15.01.2025 for assessees required to file by 31.12.2024, ensuring opportunity to exercise statutory rights.
The HC directed the respondents to modify the tax filing system for AY 2024-25 to allow assessees to claim the rebate u/s 87A of the Income Tax Act, 1961. The statutory right to claim rebate cannot be overridden by procedural changes like software utility. The rebate is linked to total income and tax liability, with the onus on tax authorities to ensure proper implementation if statutory criteria are met. Procedural impediments depriving statutory benefits warrant judicial intervention. As interim relief, the CBDT was directed to extend the due date for e-filing returns till 15.01.2025 for assessees required to file by 31.12.2024, ensuring opportunity to exercise statutory rights.
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