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...
Condonation of a 30-day delay in furnishing Form No. 10B for charitable-exemption purposes may be granted under section 119(2)(b) where refusal would cause genuine hardship. Genuine hardship must be construed liberally, with substantial justice preferred over technical non-compliance, absent deliberate delay, culpable negligence or mala fides. A bona fide misunderstanding of an advanced filing due date during the COVID-19 period, coupled with filing before the extended return due date, supported condonation. A pending condonation application did not require the charitable institution to await its disposal. Form No. 10B was treated as timely filed, and the return was to be processed accordingly.
Condonation of a 30-day delay in furnishing Form No. 10B for charitable-exemption purposes may be granted under section 119(2)(b) where refusal would cause genuine hardship. Genuine hardship must be construed liberally, with substantial justice preferred over technical non-compliance, absent deliberate delay, culpable negligence or mala fides. A bona fide misunderstanding of an advanced filing due date during the COVID-19 period, coupled with filing before the extended return due date, supported condonation. A pending condonation application did not require the charitable institution to await its disposal. Form No. 10B was treated as timely filed, and the return was to be processed accordingly.
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