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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Rectification u/s 154 - incorrect carry forward of loss - We reserve liberty to the assessee to file an application under Section 119(2)(b) of the Act before the competent authority seeking for condonation of delay in filing returns and thereafter to seek for carry forward of loss to the subsequent assessment year which were incurred during the assessment year 2004-05. If such an application is filed by the assessee within a period of two weeks from the date of receipt of certified copy of the order, the same shall be considered by the competent authority in accordance with law - HC
Rectification u/s 154 - incorrect carry forward of loss - We reserve liberty to the assessee to file an application under Section 119(2)(b) of the Act before the competent authority seeking for condonation of delay in filing returns and thereafter to seek for carry forward of loss to the subsequent assessment year which were incurred during the assessment year 2004-05. If such an application is filed by the assessee within a period of two weeks from the date of receipt of certified copy of the order, the same shall be considered by the competent authority in accordance with law - HC
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