Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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ITAT upheld grant of the concessional tax regime under section 115BAA where Form 10-IC was filed after the due date but had been furnished and was available when the return was processed. The assessee had disclosed the option in the return and the intimation under section 143(1) also recorded that option, while no other condition for the concessional rate was shown to be unfulfilled. On that basis, the CPC was required to consider the form during processing. The appellate direction to recompute tax by allowing the section 115BAA benefit was sustained and the Revenue's challenge was rejected.
ITAT upheld grant of the concessional tax regime under section 115BAA where Form 10-IC was filed after the due date but had been furnished and was available when the return was processed. The assessee had disclosed the option in the return and the intimation under section 143(1) also recorded that option, while no other condition for the concessional rate was shown to be unfulfilled. On that basis, the CPC was required to consider the form during processing. The appellate direction to recompute tax by allowing the section 115BAA benefit was sustained and the Revenue's challenge was rejected.
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