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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Validity of assessment passed w/o intimating u/s 143(1) - Denial of exemption u/s 11 and Claim of Expenses by the CPC - The Appellate Tribunal noted that the return of income and Form 10B were filed within the extended period due to the COVID-19 pandemic, as per the order of the Supreme Court. Relying on the Supreme Court's decision, the Tribunal held that there was no delay in filing the returns, and thus, the disallowance of expenses by the CPC was incorrect. The Tribunal directed the Assessing Officer to allow the exemption claimed under Section 11 of the Act.
Validity of assessment passed w/o intimating u/s 143(1) - Denial of exemption u/s 11 and Claim of Expenses by the CPC - The Appellate Tribunal noted that the return of income and Form 10B were filed within the extended period due to the COVID-19 pandemic, as per the order of the Supreme Court. Relying on the Supreme Court's decision, the Tribunal held that there was no delay in filing the returns, and thus, the disallowance of expenses by the CPC was incorrect. The Tribunal directed the Assessing Officer to allow the exemption claimed under Section 11 of the Act.
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