Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Denial of concessional tax under the 115BAA regime was addressed on whether late filing of the return u/s 139(4) precludes the option; the analysis holds that absence of an express bar prevents denial solely for filing the return belatedly and that the crucial factor is filing the option form 10IC within the prescribed period. The CBDT circular on condoning delays was deemed inapplicable because there was no delay in filing form 10IC. Procedural delay in form filing should not defeat the assessee's substantive right to concessional tax; assessee appeal allowed.
Denial of concessional tax under the 115BAA regime was addressed on whether late filing of the return u/s 139(4) precludes the option; the analysis holds that absence of an express bar prevents denial solely for filing the return belatedly and that the crucial factor is filing the option form 10IC within the prescribed period. The CBDT circular on condoning delays was deemed inapplicable because there was no delay in filing form 10IC. Procedural delay in form filing should not defeat the assessee's substantive right to concessional tax; assessee appeal allowed.
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