Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for dir...
Admissibility of a belated exercise of the option for the concessional tax regime under section 115BAA turned on procedural compliance versus substantive intention: Tribunal held that filing Form No.10IC prior to processing together with a defect-corrected/revised return demonstrated clear intention to opt for 115BAA, relied on coordinate-bench precedents favouring substance over minor procedural lapses, distinguished contrary authority on its facts, allowed the appeal and directed the Assessing Officer to verify Form No.10IC and grant the concessional regime if the form was in order.
Admissibility of a belated exercise of the option for the concessional tax regime under section 115BAA turned on procedural compliance versus substantive intention: Tribunal held that filing Form No.10IC prior to processing together with a defect-corrected/revised return demonstrated clear intention to opt for 115BAA, relied on coordinate-bench precedents favouring substance over minor procedural lapses, distinguished contrary authority on its facts, allowed the appeal and directed the Assessing Officer to verify Form No.10IC and grant the concessional regime if the form was in order.
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