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...
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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