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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Delayed filing of Form 10IC was treated as a procedural lapse where the assessee had already exercised the option for the concessional tax regime under section 115BAA in the return of income and computed tax accordingly. The Tribunal viewed Form 10IC as a mode of intimating the option, not an additional substantive when eligibility and compliance with the provision were not in dispute. The matter was remanded to the Assessing Officer to verify the filed form and grant the concessional rate in accordance with law.
Delayed filing of Form 10IC was treated as a procedural lapse where the assessee had already exercised the option for the concessional tax regime under section 115BAA in the return of income and computed tax accordingly. The Tribunal viewed Form 10IC as a mode of intimating the option, not an additional substantive when eligibility and compliance with the provision were not in dispute. The matter was remanded to the Assessing Officer to verify the filed form and grant the concessional rate in accordance with law.
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