Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
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...
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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