Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
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...
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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