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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New scheme for Tax on income of individuals and Hindu undivided family u/s 115BAC - Assessee had not filed Form 10-IE for opting the new tax regime within the stipulated time - The Appellate Tribunal referred to Section 115BAC of the Income Tax Act, which states that if an individual fails to satisfy certain conditions for opting the new tax regime, the option becomes invalid for the relevant assessment year, and the income is computed as per the old scheme. Since the assessee filed the return after the due date, the Tribunal upheld the AO's decision to assess the income under the old scheme. - Regarding denial of Deductions: the Tribunal allowed the appeal for statistical purposes, directing the assessing officer to re-examine the issue based on evidence and submissions provided by the assessee, ensuring a fair opportunity for the assessee to present their case.
New scheme for Tax on income of individuals and Hindu undivided family u/s 115BAC - Assessee had not filed Form 10-IE for opting the new tax regime within the stipulated time - The Appellate Tribunal referred to Section 115BAC of the Income Tax Act, which states that if an individual fails to satisfy certain conditions for opting the new tax regime, the option becomes invalid for the relevant assessment year, and the income is computed as per the old scheme. Since the assessee filed the return after the due date, the Tribunal upheld the AO's decision to assess the income under the old scheme. - Regarding denial of Deductions: the Tribunal allowed the appeal for statistical purposes, directing the assessing officer to re-examine the issue based on evidence and submissions provided by the assessee, ensuring a fair opportunity for the assessee to present their case.
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