Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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ITAT allowed the assessee's appeal, holding that despite initial technical difficulties in filing Form 10IE before the standard return deadline, the assessee substantially complied with statutory requirements. The tribunal recognized the extended filing period granted by CBDT and confirmed that the form was submitted before return processing. The technical glitch on the income tax portal was deemed insufficient grounds to deny tax benefit under section 115BAC, thereby granting relief to the assessee based on procedural fairness and substantive compliance with tax regulations.
ITAT allowed the assessee's appeal, holding that despite initial technical difficulties in filing Form 10IE before the standard return deadline, the assessee substantially complied with statutory requirements. The tribunal recognized the extended filing period granted by CBDT and confirmed that the form was submitted before return processing. The technical glitch on the income tax portal was deemed insufficient grounds to deny tax benefit under section 115BAC, thereby granting relief to the assessee based on procedural fairness and substantive compliance with tax regulations.
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