International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
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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