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 dismissed the petition seeking rectification of mistake in filing the wrong income tax return (ITR) format, as the assessee had full knowledge of filing the incorrect ITR. The Court observed that the assessee had filed the subsequent year's ITR in the correct format after revising it, indicating awareness of the proper procedure. The assessee has the remedy u/s 154 to seek necessary rectifications by filing an application, which the tax authority shall decide based on merits and allow the assessee to file the correct return, if required. No further adjudication by the Court is necessary at this stage.
The High Court dismissed the petition seeking rectification of mistake in filing the wrong income tax return (ITR) format, as the assessee had full knowledge of filing the incorrect ITR. The Court observed that the assessee had filed the subsequent year's ITR in the correct format after revising it, indicating awareness of the proper procedure. The assessee has the remedy u/s 154 to seek necessary rectifications by filing an application, which the tax authority shall decide based on merits and allow the assessee to file the correct return, if required. No further adjudication by the Court is necessary at this stage.
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