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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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The ITAT allowed the assessee's appeal, holding that delay in filing Form 10-IC did not disentitle the assessee to concessional taxation under s.115BAA where the form was filed for the first time before the Tribunal and the omission was explained as oversight; other grounds were consequential. The Tribunal directed the assessing officer to grant the benefit of s.115BAA if the assessee satisfies all statutory and procedural prerequisites, distinguishing revenue reliance on a decision where Form 10-IC was not filed even before the Tribunal. The relief is conditional upon fulfillment of all remaining requisite conditions.
The ITAT allowed the assessee's appeal, holding that delay in filing Form 10-IC did not disentitle the assessee to concessional taxation under s.115BAA where the form was filed for the first time before the Tribunal and the omission was explained as oversight; other grounds were consequential. The Tribunal directed the assessing officer to grant the benefit of s.115BAA if the assessee satisfies all statutory and procedural prerequisites, distinguishing revenue reliance on a decision where Form 10-IC was not filed even before the Tribunal. The relief is conditional upon fulfillment of all remaining requisite conditions.
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