Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Section 115BAB gives a new manufacturing domestic company's option continuing effect: once validly exercised in the first eligible year within time, it applies to subsequent assessment years and cannot be withdrawn. On the facts, the assessee had already exercised the option in the preceding year, so the concessional regime continued for the year under consideration. The benefit could not be denied merely because the original return for that year was later treated as invalid under section 139(9), as that technical defect did not convert the year into a fresh first-year exercise of option.
Section 115BAB gives a new manufacturing domestic company's option continuing effect: once validly exercised in the first eligible year within time, it applies to subsequent assessment years and cannot be withdrawn. On the facts, the assessee had already exercised the option in the preceding year, so the concessional regime continued for the year under consideration. The benefit could not be denied merely because the original return for that year was later treated as invalid under section 139(9), as that technical defect did not convert the year into a fresh first-year exercise of option.
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