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...
Section 119(2)(b) supports condonation where genuine hardship would otherwise result and substantial justice would be defeated by a procedural lapse. A timely original return, coupled with a bona fide correction confined to the partnership firm's nomenclature, did not alter income, tax liability, or substantive claims and caused no prejudice to the Revenue. The delay was therefore treated as arising from a purely clerical omission rather than a substantive default. Rejection of condonation was quashed, the corrected return was treated as validly filed, and it was directed to be processed in accordance with law without influence from the rejection order.
Section 119(2)(b) supports condonation where genuine hardship would otherwise result and substantial justice would be defeated by a procedural lapse. A timely original return, coupled with a bona fide correction confined to the partnership firm's nomenclature, did not alter income, tax liability, or substantive claims and caused no prejudice to the Revenue. The delay was therefore treated as arising from a purely clerical omission rather than a substantive default. Rejection of condonation was quashed, the corrected return was treated as validly filed, and it was directed to be processed in accordance with law without influence from the rejection order.
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