Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Assessee sought deduction under section 80JJAA but failed to claim it in the original return and did not file Form 10DA within the prescribed time; the tribunal applied the statutory rule that deductions under Chapter VIA require a claim in the return and concluded that section 80A(5) precludes allowance of deductions not claimed in the return. Because the claim was first made before the CIT(A) and not in the return, the deduction under section 80JJAA was disallowed.
Assessee sought deduction under section 80JJAA but failed to claim it in the original return and did not file Form 10DA within the prescribed time; the tribunal applied the statutory rule that deductions under Chapter VIA require a claim in the return and concluded that section 80A(5) precludes allowance of deductions not claimed in the return. Because the claim was first made before the CIT(A) and not in the return, the deduction under section 80JJAA was disallowed.
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