Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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Deduction under Chapter VIA for new employment could not be denied merely because Form No. 10DA was filed belatedly. The Tribunal treated the form-filing requirement as procedural, not substantive, and followed its earlier view that delay in furnishing the form does not defeat an otherwise admissible claim where no contrary material is shown. As the facts and grounds were identical for both assessment years, the same relief applied in each year. The appellate order was set aside and the Assessing Officer/CPC was directed to allow the deduction as claimed.
Deduction under Chapter VIA for new employment could not be denied merely because Form No. 10DA was filed belatedly. The Tribunal treated the form-filing requirement as procedural, not substantive, and followed its earlier view that delay in furnishing the form does not defeat an otherwise admissible claim where no contrary material is shown. As the facts and grounds were identical for both assessment years, the same relief applied in each year. The appellate order was set aside and the Assessing Officer/CPC was directed to allow the deduction as claimed.
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