Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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