Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The ITAT held that the return-filing condition introduced in section 80AC(ii), requiring a return to be filed within the time prescribed under section 139(1), applied only from 1 April 2021 and was not applicable to assessment year 2019-20. Accordingly, denial of deduction under section 80P in an intimation under section 143(1) solely because the return was filed belatedly was unsustainable, and the intimation was annulled.
The ITAT held that the return-filing condition introduced in section 80AC(ii), requiring a return to be filed within the time prescribed under section 139(1), applied only from 1 April 2021 and was not applicable to assessment year 2019-20. Accordingly, denial of deduction under section 80P in an intimation under section 143(1) solely because the return was filed belatedly was unsustainable, and the intimation was annulled.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
