Belated Form 10B filing during Covid-19 cannot defeat charitable exemption where genuine hardship warrants condonation and substantial justice prevail...
Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
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ITAT held that Rule 10CA is only a computational mechanism and does not cure functional dissimilarity, scale differences or segmental deficiencies; it therefore directed exclusion of Nihilent Technologies, Tata Elxsi, Cybage Software, Infosys, Larsen & Toubro Infotech and Wipro from the comparables set. It also held that a different financial year by itself does not vitiate comparability where public-domain data can be suitably extrapolated, and directed inclusion of R Systems International on relevant-year data. The Tribunal allowed working capital adjustment based on opening and closing balances from annual reports, and held that any separate receivables adjustment must be tested after such adjustment; if still required, interest should be benchmarked at LIBOR plus 200 basis points with a 60-day credit period.
ITAT held that Rule 10CA is only a computational mechanism and does not cure functional dissimilarity, scale differences or segmental deficiencies; it therefore directed exclusion of Nihilent Technologies, Tata Elxsi, Cybage Software, Infosys, Larsen & Toubro Infotech and Wipro from the comparables set. It also held that a different financial year by itself does not vitiate comparability where public-domain data can be suitably extrapolated, and directed inclusion of R Systems International on relevant-year data. The Tribunal allowed working capital adjustment based on opening and closing balances from annual reports, and held that any separate receivables adjustment must be tested after such adjustment; if still required, interest should be benchmarked at LIBOR plus 200 basis points with a 60-day credit period.
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