Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
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.
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