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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The High Court considered the issue of availing concessional tax rate u/s 115BAA and the requirement of electronically filing Form 10-IC. The assessee was taxed u/s 115JB for not filing Form 10-IC on time. The CIT (Appeal) upheld this decision, citing the mandatory requirement u/s 115BAA and Rule 21AE. The Tribunal found the assessee faced technical issues preventing the timely upload of Form 10-IC on the ITBA portal, despite filing it before the extended deadline. It was the first year the assessee sought such benefits. The Tribunal held that the technical error was not the fault of the assessee, allowing the benefit in the absence of any error in fact or law.
The High Court considered the issue of availing concessional tax rate u/s 115BAA and the requirement of electronically filing Form 10-IC. The assessee was taxed u/s 115JB for not filing Form 10-IC on time. The CIT (Appeal) upheld this decision, citing the mandatory requirement u/s 115BAA and Rule 21AE. The Tribunal found the assessee faced technical issues preventing the timely upload of Form 10-IC on the ITBA portal, despite filing it before the extended deadline. It was the first year the assessee sought such benefits. The Tribunal held that the technical error was not the fault of the assessee, allowing the benefit in the absence of any error in fact or law.
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