Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Where the online return-filing utility prevented a claim of set-off under s.70(2), the Court held that assessees cannot be denied a lawful claim merely because the electronic utility does not permit the prescribed computation, consistent with prior binding precedents. It directed the tax administration to modify the utility to allow the assessee to first set off STCL (STT paid) against STCG (non-STT paid) and only thereafter against STCG (STT paid). Failing timely modification, the authority was ordered to accept and process the revised return for AY 2025-26 in paper form as a valid return under s.139(5), notwithstanding the statutory e-filing mandate. - HC
Where the online return-filing utility prevented a claim of set-off under s.70(2), the Court held that assessees cannot be denied a lawful claim merely because the electronic utility does not permit the prescribed computation, consistent with prior binding precedents. It directed the tax administration to modify the utility to allow the assessee to first set off STCL (STT paid) against STCG (non-STT paid) and only thereafter against STCG (STT paid). Failing timely modification, the authority was ordered to accept and process the revised return for AY 2025-26 in paper form as a valid return under s.139(5), notwithstanding the statutory e-filing mandate. - HC
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