Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Exemption u/s 11 denied - delay in filing Form no. 10 - Department's objection that the audit report in Form no. 10B was also delayed and such delay had neither been applied for condonation of delay nor been condoned, it was the submission of the assessee that the delay in filing Form no. 10B has been condoned, in general, by the CBDT, vide Circular No. 10/2019, dated 22.5.2019, it has been stated at the Bar by the ld. Counsel for the assessee that the Audit Report in Form no. 10B had been e-filed on 4.2.2017 by the Auditor within the time prescribed under the Act, i.e., before the time prescribed for filing the return of income. - A copy of such e-verification screen-shot, having acknowledgement No. 761769971200417, has been placed on record. - Objections of the department rejected - AT
Exemption u/s 11 denied - delay in filing Form no. 10 - Department's objection that the audit report in Form no. 10B was also delayed and such delay had neither been applied for condonation of delay nor been condoned, it was the submission of the assessee that the delay in filing Form no. 10B has been condoned, in general, by the CBDT, vide Circular No. 10/2019, dated 22.5.2019, it has been stated at the Bar by the ld. Counsel for the assessee that the Audit Report in Form no. 10B had been e-filed on 4.2.2017 by the Auditor within the time prescribed under the Act, i.e., before the time prescribed for filing the return of income. - A copy of such e-verification screen-shot, having acknowledgement No. 761769971200417, has been placed on record. - Objections of the department rejected - AT
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