Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
