Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Belated filing of Form 10-IC was treated as a procedural lapse where the assessee had clearly opted for the concessional regime under section 115BAA by computing tax accordingly in the return and the form was on record when the return was processed. As the form had not been withdrawn, rejected or invalidated, and eligibility for the lower rate was undisputed, the delay did not justify denial of the statutory benefit. Tax was directed to be recomputed at the concessional rate under section 115BAA.
Belated filing of Form 10-IC was treated as a procedural lapse where the assessee had clearly opted for the concessional regime under section 115BAA by computing tax accordingly in the return and the form was on record when the return was processed. As the form had not been withdrawn, rejected or invalidated, and eligibility for the lower rate was undisputed, the delay did not justify denial of the statutory benefit. Tax was directed to be recomputed at the concessional rate under section 115BAA.
Note: It is a system-generated summary and is for quick reference only.