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 ...
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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