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...
The Tribunal held that, after substitution of section 80AC from 01.04.2018, deductions under Part C of Chapter VIA, including section 80P, are admissible only if the return is furnished within the due date under section 139(1). It accepted that this amendment applies from AY 2018-19 and followed the Madras High Court ruling in Veerappampalayam Primary Agricultural Cooperative Credit Society Ltd. A claim made only in a return filed in response to section 148, where no return had been filed within the section 139 due date, could not cure the default. The denial of deduction under section 80P was therefore sustained and the appeal dismissed.
The Tribunal held that, after substitution of section 80AC from 01.04.2018, deductions under Part C of Chapter VIA, including section 80P, are admissible only if the return is furnished within the due date under section 139(1). It accepted that this amendment applies from AY 2018-19 and followed the Madras High Court ruling in Veerappampalayam Primary Agricultural Cooperative Credit Society Ltd. A claim made only in a return filed in response to section 148, where no return had been filed within the section 139 due date, could not cure the default. The denial of deduction under section 80P was therefore sustained and the appeal dismissed.
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