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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Exemption u/s 11 - assessee has not e-filed or not filed return within due date - The NFAC/Ld.CIT(A) ruled in favor of the Assessee, stating that the CBDT circular clarified that even belatedly filed returns could be eligible for exemption under section 11, as long as filed within the time allowed under section 139. The Appellate Tribunal concurred with this decision, emphasizing the applicability of the circular and relevant case law, affirming the Assessee's eligibility for exemption under section 11.
Exemption u/s 11 - assessee has not e-filed or not filed return within due date - The NFAC/Ld.CIT(A) ruled in favor of the Assessee, stating that the CBDT circular clarified that even belatedly filed returns could be eligible for exemption under section 11, as long as filed within the time allowed under section 139. The Appellate Tribunal concurred with this decision, emphasizing the applicability of the circular and relevant case law, affirming the Assessee's eligibility for exemption under section 11.
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