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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Denial of benefit u/s 115BAA - while filing its return of income as it was unable to upload Form 10-IC due to technical glitches - Scope of CBDT circular - Despite the technical glitch in uploading Form 10-IC, the Tribunal noted that the CBDT Circular had condoned the delay in filing the form, subject to certain conditions. The Tribunal emphasized that circulars cannot curtail the benefits conferred by the law upon the assessee and should be interpreted liberally. Therefore, the Tribunal held that the appellant was entitled to the benefit under section 115BAA(1), notwithstanding the delay in uploading Form 10-IC.
Denial of benefit u/s 115BAA - while filing its return of income as it was unable to upload Form 10-IC due to technical glitches - Scope of CBDT circular - Despite the technical glitch in uploading Form 10-IC, the Tribunal noted that the CBDT Circular had condoned the delay in filing the form, subject to certain conditions. The Tribunal emphasized that circulars cannot curtail the benefits conferred by the law upon the assessee and should be interpreted liberally. Therefore, the Tribunal held that the appellant was entitled to the benefit under section 115BAA(1), notwithstanding the delay in uploading Form 10-IC.
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