Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
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...
Deductions u/s 80IB(10) - delayed filing of return - omission on the part of tax consultant due to severe ill health of his son - We do not find that the omission to file petitioner’s return by the income tax consultant to be an act of negligence. - The very fact that not only the petitioner’s ITR was not filed in time, there were also 28 others whose return filing was delayed beyond the due date. The authorities should refrain from over analysis which leads to paralysis of justice. We are, therefore, of the view that the impugned order dated 7th May 2021 deserves to be set aside and is hereby set aside. - HC
Deductions u/s 80IB(10) - delayed filing of return - omission on the part of tax consultant due to severe ill health of his son - We do not find that the omission to file petitioner’s return by the income tax consultant to be an act of negligence. - The very fact that not only the petitioner’s ITR was not filed in time, there were also 28 others whose return filing was delayed beyond the due date. The authorities should refrain from over analysis which leads to paralysis of justice. We are, therefore, of the view that the impugned order dated 7th May 2021 deserves to be set aside and is hereby set aside. - HC
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