Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Deduction under Chapter 80-series was held not forfeited by mere procedural delay in filing Form No.10CCB where the assessees filed the return within the due date and claimed the deduction; the Tribunal treated late filing of the form as a procedural defect, noting the form was uploaded before CPC processing and therefore processing under section 143(1) could not disallow the deduction solely on that ground. The Tribunal set aside the disallowance, directed recomputation of tax on book profits and remitted the matter to the AO for verification of the deduction quantum with opportunity to the assessee.
Deduction under Chapter 80-series was held not forfeited by mere procedural delay in filing Form No.10CCB where the assessees filed the return within the due date and claimed the deduction; the Tribunal treated late filing of the form as a procedural defect, noting the form was uploaded before CPC processing and therefore processing under section 143(1) could not disallow the deduction solely on that ground. The Tribunal set aside the disallowance, directed recomputation of tax on book profits and remitted the matter to the AO for verification of the deduction quantum with opportunity to the assessee.
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