Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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