Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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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TaxTMI 
TaxTMI 
of 4879 
