Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT held taxpayer eligible for new tax regime under s115BAC despite initially filing return under old regime. Filing Form 10-IE is directory rather than mandatory, provided it is available before AO during assessment. The portal's technical limitations post due date should not restrict taxpayer benefits under the new regime. CBDT Circular permits Form 10-IC/10-IE filing until 31.01.2024 or within 3 months from circular issuance. Since taxpayer's Form 10-IE for AY 2021-22 remained valid and unrevoked during assessment proceedings for AY 2022-23, benefits under new regime were upheld. The benevolent provisions must be interpreted liberally to fulfill legislative intent, not restrictively. Addition deleted accordingly.
ITAT held taxpayer eligible for new tax regime under s115BAC despite initially filing return under old regime. Filing Form 10-IE is directory rather than mandatory, provided it is available before AO during assessment. The portal's technical limitations post due date should not restrict taxpayer benefits under the new regime. CBDT Circular permits Form 10-IC/10-IE filing until 31.01.2024 or within 3 months from circular issuance. Since taxpayer's Form 10-IE for AY 2021-22 remained valid and unrevoked during assessment proceedings for AY 2022-23, benefits under new regime were upheld. The benevolent provisions must be interpreted liberally to fulfill legislative intent, not restrictively. Addition deleted accordingly.
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