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 affirms that a revised return filed within the due date which first elects the concessional regime under s.115BAA substitutes the original return and validly constitutes the s.115BAA election; the AO's characterization of such filing as a prohibited "withdrawal" is rejected. Consequent to acceptance of s.115BAA for AY 2021-22, the assessee is ineligible to claim MAT credit for that year; the AO is directed to verify any MAT credit claimed. While s.115BAA(2) bars set-off of losses attributable to specified deductions, the tribunal accepts the appellate factual finding that the assessee's brought-forward business and capital losses are not so barred and allows their set-off, upholding the CIT(A) conclusions.
ITAT affirms that a revised return filed within the due date which first elects the concessional regime under s.115BAA substitutes the original return and validly constitutes the s.115BAA election; the AO's characterization of such filing as a prohibited "withdrawal" is rejected. Consequent to acceptance of s.115BAA for AY 2021-22, the assessee is ineligible to claim MAT credit for that year; the AO is directed to verify any MAT credit claimed. While s.115BAA(2) bars set-off of losses attributable to specified deductions, the tribunal accepts the appellate factual finding that the assessee's brought-forward business and capital losses are not so barred and allows their set-off, upholding the CIT(A) conclusions.
Note: It is a system-generated summary and is for quick reference only.