Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Deductions u/s 80IC - audit report in Form 10 CCB, due to inadvertence, had not been uploaded online on time - Power of CBDT to condone delay us 119 - Rectification u/s 154 - The High Court observed that the tax authority's failure to act on the rectification request for nearly six years constituted an unreasonable refusal to exercise its statutory powers, thereby violating its duty. Errors made by the petitioner’s Chartered Accountants should not prejudice the petitioner's entitlement to statutory deductions, echoing the principle that the objective of the law is not to penalize taxpayers for inadvertent errors. The court rejected a narrow interpretation of 'genuine hardship' that would only consider severe financial crises, highlighting that the loss of statutory benefits itself constitutes a genuine hardship.
Deductions u/s 80IC - audit report in Form 10 CCB, due to inadvertence, had not been uploaded online on time - Power of CBDT to condone delay us 119 - Rectification u/s 154 - The High Court observed that the tax authority's failure to act on the rectification request for nearly six years constituted an unreasonable refusal to exercise its statutory powers, thereby violating its duty. Errors made by the petitioner’s Chartered Accountants should not prejudice the petitioner's entitlement to statutory deductions, echoing the principle that the objective of the law is not to penalize taxpayers for inadvertent errors. The court rejected a narrow interpretation of 'genuine hardship' that would only consider severe financial crises, highlighting that the loss of statutory benefits itself constitutes a genuine hardship.
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