Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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