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 assessee's claim for deduction under section 80JJAA, holding that the delayed filing of revised Form 10DA during assessment proceedings constituted a procedural lapse and could not alone defeat substantive entitlement. Citing precedent of the HC and coordinate benches, the Tribunal observed that initial non-filing before the return due date is a procedural omission; therefore the Assessing Officer should not deny the deduction solely on that ground. As the lower authorities did not examine the correctness of the claim, the ITAT remitted the matter to the AO for limited verification and quantification of the allowable deduction, directing compliance with applicable procedural safeguards.
The ITAT allowed the assessee's claim for deduction under section 80JJAA, holding that the delayed filing of revised Form 10DA during assessment proceedings constituted a procedural lapse and could not alone defeat substantive entitlement. Citing precedent of the HC and coordinate benches, the Tribunal observed that initial non-filing before the return due date is a procedural omission; therefore the Assessing Officer should not deny the deduction solely on that ground. As the lower authorities did not examine the correctness of the claim, the ITAT remitted the matter to the AO for limited verification and quantification of the allowable deduction, directing compliance with applicable procedural safeguards.
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