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...
Belated electronic filing of Form No. 9A for deemed application of charitable income may be condoned where substantial compliance and sufficient cause are established. The administrative condonation remedy under section 119(2)(b) is additional and does not bar appellate consideration of an exemption claim after administrative condonation is refused. Filing during assessment proceedings in the first year of mandatory electronic filing, without evidence of deliberate or mala fide delay, supported condonation of the short delay. The delayed Form No. 9A was treated as valid, and the deemed-application claim was directed to be considered after verification of the remaining statutory conditions and a hearing.
Belated electronic filing of Form No. 9A for deemed application of charitable income may be condoned where substantial compliance and sufficient cause are established. The administrative condonation remedy under section 119(2)(b) is additional and does not bar appellate consideration of an exemption claim after administrative condonation is refused. Filing during assessment proceedings in the first year of mandatory electronic filing, without evidence of deliberate or mala fide delay, supported condonation of the short delay. The delayed Form No. 9A was treated as valid, and the deemed-application claim was directed to be considered after verification of the remaining statutory conditions and a hearing.
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