Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Dominant issue: whether the taxpayer could claim the new tax regime under section 115BAC despite delayed filing of Form 10-IE and a slightly late return. Reasoning: while jurisprudence treats late Form 10-IE as a procedural lapse that ordinarily should not forfeit the new regime, the return itself was filed late, rendering the new-regime option infirm and requiring reassessment under the old regime. Outcome: matter remanded to the Assessing Officer to admit and verify alternative claims for deductions under sections 80C and 80TTA and grant relief if substantiated; appeal allowed for statistical purposes. - ITAT
Dominant issue: whether the taxpayer could claim the new tax regime under section 115BAC despite delayed filing of Form 10-IE and a slightly late return. Reasoning: while jurisprudence treats late Form 10-IE as a procedural lapse that ordinarily should not forfeit the new regime, the return itself was filed late, rendering the new-regime option infirm and requiring reassessment under the old regime. Outcome: matter remanded to the Assessing Officer to admit and verify alternative claims for deductions under sections 80C and 80TTA and grant relief if substantiated; appeal allowed for statistical purposes. - ITAT
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