Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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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