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 address the rejection of revision petition u/s 264 due to an inadvertent error in filing Form ITR-VII, resulting in denial of exemption to a trust approved u/s 10(23C) of the Income-tax Act. The court found that the Trust was entitled to exemption as there was no indication otherwise. The respondent's rejection based on filing errors without considering the exemption claim requires reconsideration. The court set aside the order and remanded the matter for reconsideration, directing the respondent to issue a fresh order within three months considering the court's observations.
The High Court address the rejection of revision petition u/s 264 due to an inadvertent error in filing Form ITR-VII, resulting in denial of exemption to a trust approved u/s 10(23C) of the Income-tax Act. The court found that the Trust was entitled to exemption as there was no indication otherwise. The respondent's rejection based on filing errors without considering the exemption claim requires reconsideration. The court set aside the order and remanded the matter for reconsideration, directing the respondent to issue a fresh order within three months considering the court's observations.
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