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 of reduced rate of tax @22% - Domestic Companies - Condonation of delay in filing of Form No. 10-IC by the assessee - The Appellate Tribunal carefully evaluates the submissions and the provisions of Circular No. 19/2023. It observes that the assessee has indeed fulfilled all the conditions mentioned in the circular for condoning the delay in filing Form No. 10-IC. Firstly, the assessee filed its income tax return within the due date specified under Section 139(1) of the Income Tax Act. Secondly, the option for taxation under Section 115BAA was duly exercised by the assessee in the filed return. Lastly, Form No. 10-IC was electronically filed within the extended timeline provided by the circular. - Given that the assessee has met all the prescribed conditions, the Appellate Tribunal concludes that the delay in filing Form No. 10-IC should be condoned.
Denial of benefit u/s 115BAA of reduced rate of tax @22% - Domestic Companies - Condonation of delay in filing of Form No. 10-IC by the assessee - The Appellate Tribunal carefully evaluates the submissions and the provisions of Circular No. 19/2023. It observes that the assessee has indeed fulfilled all the conditions mentioned in the circular for condoning the delay in filing Form No. 10-IC. Firstly, the assessee filed its income tax return within the due date specified under Section 139(1) of the Income Tax Act. Secondly, the option for taxation under Section 115BAA was duly exercised by the assessee in the filed return. Lastly, Form No. 10-IC was electronically filed within the extended timeline provided by the circular. - Given that the assessee has met all the prescribed conditions, the Appellate Tribunal concludes that the delay in filing Form No. 10-IC should be condoned.
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