Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
CBDT Circular No. 13/2023 specifically governs condonation applications by co-operative societies that filed delayed returns while claiming deduction under section 80P for covered assessment years, displacing the general framework in Circular No. 09/2015 for refunds and loss carry-forwards. Reliance solely on the general circular without considering the specific circular reflects non-application of mind. COVID-19 restrictions and delayed statutory audit reports routed through the State Audit Department may constitute genuine hardship under Circular No. 13/2023. Condonation relief under section 119(2)(b) should be applied liberally rather than defeated on a hyper-technical basis, enabling consideration of a qualifying section 80P claim on merits.
CBDT Circular No. 13/2023 specifically governs condonation applications by co-operative societies that filed delayed returns while claiming deduction under section 80P for covered assessment years, displacing the general framework in Circular No. 09/2015 for refunds and loss carry-forwards. Reliance solely on the general circular without considering the specific circular reflects non-application of mind. COVID-19 restrictions and delayed statutory audit reports routed through the State Audit Department may constitute genuine hardship under Circular No. 13/2023. Condonation relief under section 119(2)(b) should be applied liberally rather than defeated on a hyper-technical basis, enabling consideration of a qualifying section 80P claim on merits.
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