Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
A rectification grievance under section 154 concerning a return treated as invalid for want of an audit report had to be examined on merits by verifying whether the assessee had any income from business or profession and, if not, whether any audit report was required. The Tribunal found that the authorities had not adjudicated this plea and had instead shifted the matter between CPC and the jurisdictional AO on jurisdictional grounds. The mechanical rejection was set aside, and the matter was restored to the jurisdictional AO for proper verification and consequential relief if the return was wrongly invalidated.
A rectification grievance under section 154 concerning a return treated as invalid for want of an audit report had to be examined on merits by verifying whether the assessee had any income from business or profession and, if not, whether any audit report was required. The Tribunal found that the authorities had not adjudicated this plea and had instead shifted the matter between CPC and the jurisdictional AO on jurisdictional grounds. The mechanical rejection was set aside, and the matter was restored to the jurisdictional AO for proper verification and consequential relief if the return was wrongly invalidated.
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