Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The ITAT allowed the appeal, holding that the assessee remains entitled to the deduction under section 80IC where the claim was made in the original return of income filed under section 139(1) and persisted in the revised return under section 139(5). The Tribunal held that the statutory requirement to claim the deduction pertains to submission in the return as governed by section 80AC and that revision under section 139(5) does not by itself bar the claim. Further, delay in submission of the statutory audit report (Form 10CCB) was held to be directory rather than mandatory if the audit report is furnished prior to completion of assessment. Grounds raised by the assessee were allowed.
The ITAT allowed the appeal, holding that the assessee remains entitled to the deduction under section 80IC where the claim was made in the original return of income filed under section 139(1) and persisted in the revised return under section 139(5). The Tribunal held that the statutory requirement to claim the deduction pertains to submission in the return as governed by section 80AC and that revision under section 139(5) does not by itself bar the claim. Further, delay in submission of the statutory audit report (Form 10CCB) was held to be directory rather than mandatory if the audit report is furnished prior to completion of assessment. Grounds raised by the assessee were allowed.
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