Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Delay in filing Form 10-IC for the concessional corporate tax regime may be condoned where the return was filed on time, the option was disclosed in the return, tax was paid at the concessional rate, and the omission was a bona fide lapse. The HC treated the delay as a case of genuine hardship, noting that the relevant circulars showed an intent to grant relief in fit cases, including the period affected by COVID-19 and the initial years of the regime. It held that the authority should have taken a justice-oriented approach rather than reject condonation on the basis that a tax manager's or consultant's lapse could never justify relief. The rejection and consequential denial of the benefit were set aside.
Delay in filing Form 10-IC for the concessional corporate tax regime may be condoned where the return was filed on time, the option was disclosed in the return, tax was paid at the concessional rate, and the omission was a bona fide lapse. The HC treated the delay as a case of genuine hardship, noting that the relevant circulars showed an intent to grant relief in fit cases, including the period affected by COVID-19 and the initial years of the regime. It held that the authority should have taken a justice-oriented approach rather than reject condonation on the basis that a tax manager's or consultant's lapse could never justify relief. The rejection and consequential denial of the benefit were set aside.
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