Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Belated filing of Form 10CCB did not, by itself, justify denial of deduction under section 80IA where the return was filed in time and the audit report was on record before processing under section 143(1). The Tribunal held that filing Form 10CCB by the due date is a procedural requirement, and once the report was furnished before issuance of the intimation, the CPC was bound to examine it. On that basis, the Commissioner (Appeals)' order allowing the deduction was upheld and the Revenue's challenge to the disallowance failed.
Belated filing of Form 10CCB did not, by itself, justify denial of deduction under section 80IA where the return was filed in time and the audit report was on record before processing under section 143(1). The Tribunal held that filing Form 10CCB by the due date is a procedural requirement, and once the report was furnished before issuance of the intimation, the CPC was bound to examine it. On that basis, the Commissioner (Appeals)' order allowing the deduction was upheld and the Revenue's challenge to the disallowance failed.
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