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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Rejection of application u/s 119(2)(b) for condoning the delay in filing the Form 10B - delay was about 1257 days - Exemption u/s 10(23C) - assessment of trust - The High Court noted that the petitioner had a history of timely compliance with filing returns and Form 10B for other assessment years. Considering this, the Court inferred that the failure to file for the relevant assessment year was likely due to human error. The Court referred to a similar case where delay due to oversight by the auditor was accepted as reasonable cause. Ultimately, the Court allowed the writ petition, quashing the order of the revenue authority and condoning the delay in filing Form 10B.
Rejection of application u/s 119(2)(b) for condoning the delay in filing the Form 10B - delay was about 1257 days - Exemption u/s 10(23C) - assessment of trust - The High Court noted that the petitioner had a history of timely compliance with filing returns and Form 10B for other assessment years. Considering this, the Court inferred that the failure to file for the relevant assessment year was likely due to human error. The Court referred to a similar case where delay due to oversight by the auditor was accepted as reasonable cause. Ultimately, the Court allowed the writ petition, quashing the order of the revenue authority and condoning the delay in filing Form 10B.
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