Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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